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John Anthony Castro
Castro & Co. is a U.S. firm specializing exclusively in international taxation.
For private individual clientele, we provide numerous tax planning and estate planning services. For non-U.S. individuals considering entering the U.S. on a business or investor visa, we do pre-visa tax planning to avoid many U.S. tax traps, such as the U.S. inheriting the taxability of built-in gains in worldwide assets. We can also structure our clients' affairs to be treated as a nonresident for tax purposes. For U.S. individuals considering investing or doing business overseas, we structure business operations in a highly tax-efficient manner.
We also assist individuals and companies in deferring U.S. taxation on foreign-source income by keeping those profits overseas and out of the taxing jurisdiction of the U.S. (Subpart F Avoidance), planning to utilize excess foreign tax credits through planning strategies (Excess FTC Planning), designing finance/IP license/service arrangements that result in a reduction of taxable income in a particular country (Base Erosion and Profit Shifting), transferring tangible and intangible assets to an offshore company (Transfer Pricing), and moving an entire company offshore (Corporate Inversion).
What separates our work-product from others is that we make sure our clients' plans will survive IRS scrutiny by including a substantial degree of economic substance in all arrangements. In other words, we develop the kind of plan a client could comfortably disclose to the IRS without the least bit of concern. We provide results; not merely services.
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