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Posts in February, 2019

  • Capital Gains and Losses form
    Feb 22 Treaty-Based Synthetic Basis Step-Up Election for Australian Nationals

    by John Anthony Castro, J.D., LL.M. Introduction One issue that comes up quite frequently from Australian nationals in the U.S. is ...

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  • Courthouse
    Feb 21 The UK LTA Charge Can Be Claimed as a U.S. Foreign Tax Credit

    by John Anthony Castro, J.D., LL.M. About the Author John Anthony Castro , J . D ., LL . M ., is the Managing Partner of Castro & ...

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  • HM Revenue & Customs paperwork
    Feb 18 U.S. Roth Accounts are Exempt from UK Tax | QROP Loophole | Hopscotch U.S. Extraction

    by John Anthony Castro, J.D., LL.M. UPDATE Please note that the HMRC is not approving any new QROP applications for U.S.-based ...

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  • Feb 08 The 2019 Offshore Voluntary Disclosure Program | 2019 OVDP

    by John Anthony Castro, J.D., LL.M. Introduction On November 20, 2018, the Deputy Commissioner for Services and Enforcement, ...

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  • Feb 07 The Treaty Definition of a Permanent Establishment

    Introduction We advise clients worldwide on structuring operations to avoid the finding of a permanent establishment. Contact us ...

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  • Family members cheers
    Feb 06 Section 267(b)(1) Related Family Members

    Introduction Section 267(b) is referenced in 79 sections throughout the Internal Revenue Code as well as 175 state law provisions ...

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