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The Definition of a U.S. Tax Resident – Not As Simple As You Think
Four “bright line” tests determine tax residency in the United States: (1) United States citizenship, (2) lawful admission for permanent residence ...
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Castro & Co.
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The Section 199A Qualified Business Income Deduction
There is a lot of confusion surrounding the new Section 199A Qualified Business Income Deduction . Thankfully, our firm has finally completed a ...
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Castro & Co.
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The Necessity of Tax Opinions
In a recent 2018 federal court case, a company, Alternative Carbon Resources LLC, was assessed $39 million in penalties despite the fact that the ...
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Castro & Co.
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Claim a Refund for the Section 965 Tax
This article is intended to synthesize 5 other articles and explain our firm’s legal position on how family companies can claim a refund for the ...
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Castro & Co.
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How to Sue the IRS: An Explanation of Tax Litigation
Introduction Most people don’t think of suing the IRS let alone the U.S. government, but we live in a healthy democracy and a significant aspect of a ...
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Castro & Co.
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Pre-Residency Tax Planning with the Check-and-Liquidate Strategy
The “check-and-liquidate” strategy is a pre-residency tax planning strategy pioneered by our firm as a result of a court case titled Dover v. ...
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Castro & Co.
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The Art of the Silent Treaty Position
As of today, the prevailing wisdom is that, due to treaty “Saving Clauses,” U.S. citizens are generally prohibited from enjoying most of the benefits ...
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Castro & Co.
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The Benefits of Social Security Totalization Agreements
Finally, the internet now has a comprehensive guide to social security totalization agreements. You’re welcome. Introduction The President of the ...
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Castro & Co.
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