Posts in International Tax

Oct 12 The PFIC Loophole the IRS Doesn’t Want You to Know About

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

Jul 02 COVID-19 Relief for Entities with Income Not Effectively Connected to U.S. Trade or Business

by Katherine Jean Barnes, J.D., LL.M. IRS: FAQs for Nonresident Alien Individuals and Foreign Businesses with Employees or Agents ...

Mar 23 New IRS Guidance Regarding Certain Tax-Favored Foreign Trusts

by John Anthony Castro, J.D., LL.M. In new IRS guidance, certain foreign trusts receive a significant break from information ...

Mar 14 Draft Regulations for Form 3520

by John Anthony Castro, J.D., LL.M. Castro Exclusive Castro & Co. has a draft version of regulations under Internal Revenue Code ...

Mar 07 Foreign Grantor Trusts Explained

Foreign Grantor Trusts Explained by John Anthony Castro, J.D., LL.M. Whenever a tax professional doesn’t know what to call ...

Mar 02 Castro Special Report | IRS Release New Rev. Proc. 2020-17 Exemptions to Form 3520 Foreign Trust Reporting

by John Anthony Castro, J.D., LL.M. Introduction The IRS created new exemptions for U.S. taxpayers that have transactions with ...