Blog Home Recent Posts in the Litigation Category The Constitutionality of Retroactive Tax Legislation Feb 6, 2020 by John Anthony Castro, J.D., LL.M. Introduction It has long been declared that “the power of Congress to enact income tax laws with retroactive ... Posted By Castro & Co. Continue Reading Step-by-Step Guide to Challenging the Validity of a Treasury Regulation Oct 8, 2019 by John Anthony Castro, J.D., LL.M. One question that comes up quite often with our clients is why some of our legal positions are contrary to ... Posted By Castro & Co. Continue Reading Pursuing a Claim of Refund in Federal Court Jul 9, 2019 by John Anthony Castro, J.D., LL.M. The first step in filing a claim for refund against the IRS is to file either a Form 1040X, Amended U.S. Federal ... Posted By Castro & Co. Continue Reading The Myth of Downward Attribution Jun 18, 2019 by John Anthony Castro, J.D., LL.M. Background I. Controlled Foreign Corporations As a general rule, foreign corporations are not subject to the ... Posted By John Anthony Castro Continue Reading Page of 5