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The 2019 Offshore Voluntary Disclosure Program
by John Anthony Castro, J.D., LL.M. Introduction On November 20, 2018, the Deputy Commissioner for Services and Enforcement, Kirsten B. Wielobob, ...
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John Anthony Castro, J.D., LL.M.
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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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Castro & Co.
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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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Castro & Co.
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How to Sue the IRS: An Explanation of Tax Litigation
Introduction Most people don’t think of suing the IRS let alone the U.S. government, but we live in a healthy democracy and a significant aspect of a ...
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Castro & Co.
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New VA Regulations Are Invalid
Introduction Government agencies have several restrictions on promulgating regulations. First, the regulation must be clarifying a statute that is ...
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Castro & Co.
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The Legality of Retroactive Treasury Regulations
One of the most common questions we get from clients that are themselves tax attorneys or CPAs is whether the U.S. Department of the Treasury can ...
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Castro & Co.
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Section 965 Deemed Repatriation Tax: Defeated
There was once a time when everyone was wholly convinced that the world was flat. This is a phrase we often repeat to skeptics. Today, the prevailing ...
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Castro & Co.
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The Cohan Rule in 2018
In accordance with the principles for claiming deductions, the burden of proof is on a taxpayer when claiming business deductions under Section ...
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Castro & Co.
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