Posts in January, 2019

Jan 31 Reasonable Cause to Avoid Tax Penalties

by John Anthony Castro, J.D., LL.M. Introduction Reasonable Cause is based on objective facts and circumstances. Rather than ...

Jan 12 The Definition of a U.S. Tax Resident - Not As Simple As You Think

by John Anthony Castro, J.D., LL.M. Four “bright line” tests determine tax residency in the United States: (1) United States ...

Jan 09 The Section 199A Qualified Business Income Deduction

by John Anthony Castro, J.D., LL.M. Introduction The purpose of this article is to first understand and establish that doctors, ...

Jan 08 The Necessity of Tax Opinions

by John Anthony Castro, J.D., LL.M. Introduction Our firm focuses on researching the latest tax issues and developing ...

Jan 07 Claim a Refund for the Section 965 Tax

by John Anthony Castro, J.D., LL.M. Update 1/6/2021: Please note that the statutory deadline to either judicially challenge the ...

Jan 04 Pre-Residency Tax Planning with the Check-and-Liquidate Strategy

by John Anthony Castro, J.D., LL.M. Introduction The “check-and-liquidate” strategy is a pre-residency tax planning strategy ...