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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 reading for hours and ...
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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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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, lawyers, investment ...
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The Necessity of Tax Opinions
by John Anthony Castro, J.D., LL.M. Introduction In a recent 2018 federal court case, a company, Alternative Carbon Resources LLC, was assessed $39 ...
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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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How to Sue the IRS: An Explanation of Tax Litigation
by Kathryn Nicole Magan, J.D . Introduction Most people don’t think of suing the IRS let alone the U.S. government, but we live in a healthy democracy ...
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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 pioneered by our firm as ...
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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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