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Reasonable Cause to Avoid Tax Penalties
Introduction What constitutes “reasonable cause” under Code section 6651 for purposes of avoiding penalties for failure to file a tax return or pay ...
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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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ESBT and QSST Elections: How to Qualify Trusts as S Corporation Shareholders
An S corporation election is a special election that may be made by businesses seeking corporate treatment for tax, liability, or asset protection ...
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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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International Estate Planning in Plain English
International Estate Planning in Plain English: The Most Comprehensive Online Guide in the World by John Anthony Castro, J.D., LL.M. I.INTERNATIONAL ...
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Pre-Immigration Tax Planning: Three Common Myths
When the subject of pre-immigration tax planning comes up most people, including many practitioners, will mention their understanding that effective ...
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Castro & Co.
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4 Things You Need to Know About International Estate Planning
Whether you are a U.S. citizen residing in a foreign country or a non-U.S. citizen needing help with estate planning in the United States, our firm ...
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Castro & Co.
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IRS Gains the Power to Revoke U.S. Passports for Tax Debts
The President signed into law a new provision to the Internal Revenue Code that gives the U.S. government the right to revoke or deny the renewal of ...
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Castro & Co.
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