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The IRS Has Ended the Offshore Voluntary Disclosure Program
The Internal Revenue Service (IRS) has announced that they have formally ended the Offshore Voluntary Disclosure Program (OVDP) effective September ...
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Castro & Co.
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Foreign LLC-Equivalents are Flow-Through by Default
Generally, courts will give deference to an executive department’s interpretation of a statute they are tasked with enforcing. This is referred to as ...
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Castro & Co.
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Lunches with Colleagues Are Deductible as Business Meals
Section 274 has been misinterpreted and misapplied for decades. This article applies for tax years 2017 and prior. General Scope and Purpose of ...
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Castro & Co.
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Nonresident Individual Income and Transfer Taxation in the United States
I. Introduction The goal of this article is to provide an introduction and overview of United States federal tax rules for the estate, gift, and ...
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Understanding Business Purpose and Schedule C
Under Section 162, a taxpayer can deduct all ordinary and necessary expenses related to a trade or business. [1] For the expense to be deductible, it ...
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Castro & Co.
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The Legality of Retroactive Treasury Regulations
One of the most common questions we get from clients that are themselves tax attorneys or CPAs is whether the U.S. Department of the Treasury can ...
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Castro & Co.
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Pet Trusts
Pet ownership is on the rise in America. For some this is no surprise as new benefits of pet ownership are being proven. We have always known that ...
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Castro & Co.
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Taking Care with S Corporation Trusts
When it comes to trusts being eligible S corporation shareholders the rules concerning how a trust qualifies, what trusts qualify, and implications to ...
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Castro & Co.
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