Posts in Litigation

May 12 Protecting Your Organization Against Paycheck Protection Program Qui Tam Actions

by John Anthony Castro, J.D., LL.M. Most companies thought the “hard part” was over when they received loans under the Paycheck ...

Feb 06 The Constitutionality of Retroactive Tax Legislation

by John Anthony Castro, J.D., LL.M. Introduction It has long been declared that “the power of Congress to enact income tax laws ...

Oct 08 Step-by-Step Guide to Challenging the Validity of a Treasury Regulation

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 ...

Jul 08 Pursuing a Claim of Refund in Federal Court

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, ...

Jun 18 The Myth of Downward Attribution

by John Anthony Castro, J.D., LL.M. Background I. Controlled Foreign Corporations As a general rule, foreign corporations are not ...

Feb 08 The 2019 Offshore Voluntary Disclosure Program | 2019 OVDP

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