

Andrea Ricci
International Tax CPA
Make sure to stay tuned for my latest business insights and updates!






Non-U.S. corporations and other corporate entities with income effectively connected with a U.S. trade or business (ECI income) must file Form 1120-F with the IRS and pay any associated U.S. tax liability calculated at the regular corporate income tax rate at 21%. It's important to understand that the U.S. corporate income tax is computed on a net income basis, which ensures a fair and transparent tax system. Any expense related to the production of the ECI income can be deducted from gross receipts earned in the USA.
Form 1120-F
Non-US resident individuals earning income that is effectively connected with a U.S. trade or business (ECI income) must file Form 1040-NR with the IRS. ECI income taxation for non-resident individuals is done on a net basis, which means you can deduct certain expenses related to the production of your U.S. ECI. This can significantly reduce your tax burden. If you have a sole proprietorship, or a single-member LLC, or U.S. real property investments, you are likely under the obligation to file Form 1040-NR with the IRS.
Form 1040-NR
IRS Form W8 (i.e., Form W8BEN for individuals and Form W8BENE for corporate entities) is a powerful tool whenever a non-U.S. taxpayer earns passive income (FDAP income) from a source within the United States. This form, when completed, allows foreign nationals and entities to claim tax treaty benefits. These benefits include a reduced withholding tax rate at source on certain payments, like dividends, interest, royalties, wages, etc. By understanding and using this form, you can empower yourself with the knowledge to optimize your tax situation.
Form W8
Non-U.S. banks and financial institutions are required to comply with specific FATCA tax reporting requirements for financial accounts held by U.S. citizens and tax residents. If they fail to comply with FATCA, they may face an additional 30% withholding tax on certain payments received from U.S. individuals and entities, even those made on behalf of their clients. Each non-U.S. bank or financial institution must register with the IRS Portal and obtain a Global Intermediary Identification Number (GIIN).
FATCA
Investing in US Real Estate presents an exciting opportunity for many investment managers and wealthy individuals. The potential benefits, such as high returns and a stable market, can be a source of optimism and hope. However, foreign investors in US real property interest must pay careful attention to their US income tax obligations in order to avoid hefty penalties. Under FIRPTA (Foreign Investment in Real Property Act), any gain arising on the disposition of a direct, or indirect, "U.S. real property interest" is automatically treated as effectively connected income (ECI income) and is accordingly taxed in the United States.
Real Estate
Non-U.S. individuals with personal or real property in the United States are subject to an up to 40% estate tax upon death. It's crucial to be aware that holding assets in the United States can expose them to unwanted tax consequences. This underscores the necessity of appropriate international tax planning. Depending on the nature of the assets held in the United States and on the taxpayer's tax residence, these strategies can be used to minimize the estate tax liability. Depending on applicable double tax treaties with the United States, obtaining a foreign tax credit for the foreign estate tax paid abroad may also be possible.
Estate & Gift Tax
U.S. citizens and residents residing abroad face several tax challenges arising from the complexity of U.S. international tax law. However, the Internal Revenue Code also extends several significant tax benefits to American businesses with global operations. As an international tax CPA, I have extensive expertise in the reporting requirements for Controlled Foreign Companies (CFCs) using IRS Form 5471, as well as the taxation of Passive Foreign Investment Companies (PFICs) through IRS Form 8621 and other favorable tax elections. With proper international tax planning, you can also take advantage of the GILTI and FDII deductions.
U.S. International Tax
Having an offshore or U.S. company can provide various advantages for global investors, but these benefits only apply if the company complies fully with local accounting requirements. Maintaining adequate books and records is essential for any business.
Non-U.S. investors with a company registered in the United States are required to file IRS Form 5472. This form must disclose any transactions between the U.S. company and its key foreign owners. Likewise, U.S. investors who own a significant amount of stock in a foreign corporation or have an interest in a foreign partnership must accurately track the earnings and profits (E&P) of the foreign entity.
Regardless of your tax status, it is crucial to keep precise records of all transactions if you have an offshore company in any jurisdiction.
Accounting
Tax & Accounting Services
by a Certified Public Accountant

I believe that each client is unique, deserving of a personalized US CPA service that truly helps them achieve their goals.
International Tax CPA Service

I am truly international in every possible way, and I can meet you anywhere in the world.
I speak English, Spanish, Italian, and Russian.
Global Outreach

I believe in utilizing the most current and reliable technology to connect with my clients worldwide, and to generate the most comprehensive and accurate work products. In addition, security and confidentiality of client information are my top priorities. I utilize encrypted mailing systems and cutting-edge firewalls to safeguard my clients' data.
Technology & Security
What sets me apart from others?
"The wise man bridges the gap by laying out the path by means of which he can get from where he is to where he wants to go"
John Pierpont Morgan
Are you seeking assistance for your international business journey?
My name is Andrea Ricci. I am a seasoned certified public accountant (CPA), member of the AICPA, and trade professional with over a decade of experience in international tax, accounting, and overseas trade consulting. I graduated from Bocconi University in Milan, Italy and worked my way up in the European financial industry from 2014 to 2021. After that, I successfully passed the Uniform CPA Examination in the USA and started my own practice, where I help international entrepreneurs grow their businesses across borders. My area of specialty is international tax planning, and I have extensive knowledge of US tax law and European tax directives.
Andrea Ricci CPA

