John Anthony Castro is a colorful character. He entered several Republican primaries seeking the Presidential slot after failing to win the primary for a Senate seat representing Texas. He sued to have our once and future President Donald Trump be removed from the ballot on Fourteenth Amendment Section 3 grounds. As we can easily infer, those suits went nowhere. But more than anything, John Anthony Castro was a tax guy with a virtual practice with locations in four cities. Not anymore. Now he is resident in a Bureau of Prisons facility – the Federal Medical Center Fort Worth. On October 30, 2024, Judge Terry Means sentenced Castro to 188 months in prison, followed by one year of supervised release and restitution of $277,243, following his conviction on 33 counts of “Aiding and Assisting in the Preparation and Presentation of a False and Fraudulent Return." Does the sad story of John Anthony Castro hold any lessons for us? Perhaps.
Reassessing R&D Structures After the Section 174 Changes
Ted Stotzer
Recent changes to the tax treatment of research and experimental (“R&E”) expenditures may warrant a fresh look at existing intellectual property (“IP”) and research and development (“R&D”) structures. This article examines whether taxpayers should revisit decisions regarding the location of R&D activities, IP ownership, contract R&D arrangements, and related transfer pricing policies in light of the evolving legislative landscape, and how the interaction of Sections 174, 168(k), 59(e), and 163(j) can be used to calibrate a tax-efficient result.
