Recent Posts in the Litigation Category

• 
  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. UPDATE On October 1, 2019, the IRS announced it had released Revenue Procedure 2019-40 , which outlined the safe ...

  Posted By John Anthony Castro

  Continue Reading
• 
  The 2019 Offshore Voluntary Disclosure Program | 2019 OVDP

  Feb 8, 2019

  by John Anthony Castro, J.D., LL.M. Introduction On November 20, 2018, the Deputy Commissioner for Services and Enforcement, Kirsten B. Wielobob, ...

  Posted By John Anthony Castro, J.D., LL.M.

  Continue Reading