Recent Posts in January, 2015

• The Definition of Willfulness in OVDP and Streamlined Cases
  Jan 25, 2015
  Last Updated: January 15, 2019 What constitutes “willful” in determining the meaning of the term “non-willful” as used by the Internal Revenue Service ...
  Posted By Castro & Co.
  Continue Reading
• Global Tax Enforcement - Another Example of Why You Need a Tax Attorney
  Jan 21, 2015
  On October 20, 2014, Menashe Cohen pleaded guilty in New Hampshire federal court to one count of filing a false income tax return for failing to ...
  Posted By Castro & Co.
  Continue Reading
• The OECD Report on Base Erosion and Profit Shifting
  Jan 4, 2015
  In February of 2014, the Organization for Economic Cooperation and Development (OECD) published a report titled Addressing Base Erosion and Profit ...
  Posted By Castro & Co.
  Continue Reading
• Fifth Amendment Protection for Your Offshore Bank Records?
  Jan 2, 2015
  One of the most frequent questions I get from private clients is whether they can assert their Fifth Amendment Right to Avoid Self-Incrimination when ...
  Posted By Castro & Co.
  Continue Reading
• Switzerland and China Sign New Income Tax Treaty
  Jan 2, 2015
  Switzerland and China have signed a new Income and Capital Tax Treaty that, once in force and effective, will replace the old treaty of 1990. The new ...
  Posted By Castro & Co.
  Continue Reading
• 2014 Inflation Adjustments for Individuals Regarding International Tax Matters
  Jan 1, 2015
  The IRS recently published Revenue Procedure 2013-35, setting forth inflation adjusted items for tax year 2014. With regard to international tax ...
  Posted By Castro & Co.
  Continue Reading