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Investing in a U.S. Real Estate Partnership as a Foreign Investor? Here's What you Need To Know
Investing in U.S. real estate presents a valuable opportunity for foreign investors eager to diversify their portfolios and tap into one of the world's largest property markets. Yet, the complex tax landscape that accompanies such investments can be daunting.

Andrea Ricci, CPA
Sep 20, 20255 min read


Understanding Form 5472 and Its IRS Filing Requirements
If you are a foreign owner of a business operating in the U.S., you may feel overwhelmed by the tax requirements. One important form you must understand is Form 5472

Andrea Ricci, CPA
Aug 29, 20254 min read


Understanding ITIN: A Comprehensive Guide to Obtaining One Through a CAA
In today's global economy, understanding taxation can feel overwhelming, especially for non-resident aliens and foreign nationals living in the United States. A crucial tool in this process is the Individual Taxpayer Identification Number (ITIN).

Andrea Ricci, CPA
Aug 21, 20255 min read


FDEI Under OBBBA: America’s New Export-Friendly Tax Break
The long-standing Foreign-Derived Intangible Income (FDII) regime, often criticized for its complexity and its awkward treatment of tangible investments, was replaced with something simpler, more predictable, and arguably more potent: Foreign-Derived Deduction Eligible Income (FDEI).

Andrea Ricci, CPA
Aug 12, 20252 min read


How GILTI Changed After the One Big Beautiful Bill Act (OBBBA)
The Global Intangible Low-Taxed Income (GILTI) regime, introduced under the 2017 Tax Cuts and Jobs Act (TCJA), was significantly revised by the One Big Beautiful Bill Act (OBBBA)—a sweeping reform package passed in 2025 that reshaped international taxation for U.S. multinationals and investors.

Andrea Ricci, CPA
Aug 5, 20253 min read


Understanding the Proper Chapter 4 Classification for W8-BEN-E Compliance and International Taxation
The W8-BEN-E form serves as a key document for foreign entities aiming to benefit from reduced withholding rates under U.S. tax treaties. Accurately classifying under Chapter 4 for W8-BEN-E compliance is critical for organizations

Andrea Ricci, CPA
Jul 16, 20254 min read


2025 U.S. International Tax Reform: What is changing?
A summary of the key changes to the U.S. international tax regime introduced by the One Big Beautiful Bill Act of 2025 (Budget Reconciliation Bill).

Andrea Ricci, CPA
Jul 5, 20252 min read


What Is Treaty Shopping, and Why Might a Foreign Holding Company Be Denied U.S. Tax Treaty Benefits?
Treaty shopping has gained significant attention in the realm of international tax law. Many foreign holding companies seek to leverage U.S. tax treaties to reduce their tax obligations on income earned in the United States

Andrea Ricci, CPA
Jun 26, 20254 min read


What Are IRS Streamlined Foreign Offshore Procedures ?
To assist Americans living overseas, the IRS offers several compliance programs, one of which is the Streamlined Foreign Offshore Procedures. But what does this entail?

Andrea Ricci, CPA
Jun 8, 20254 min read


How to Claim Reduced U.S. Withholding Tax on Interest and Dividends
Claiming reduced withholding tax on interest and dividends can have a significant impact on your investment income. For non-U.S. residents, understanding the regulations surrounding this tax is crucial.

Andrea Ricci, CPA
May 28, 20253 min read


Understanding the Portfolio Interest Exemption from U S Withholding Tax for Nonresident Investors
A key element that nonresidents should understand is the portfolio interest exemption from U.S. withholding tax

Andrea Ricci, CPA
May 1, 20254 min read


Can Luxembourg Investment Companies Access Luxembourg USA DTA Benefits?
In today's interconnected world, tax treaties play a key role in facilitating international investments

Andrea Ricci, CPA
Apr 26, 20253 min read


Exploring States That Exempt Foreign-Source Income from Taxation and Their Impact on Business Formation
In the complex world of U.S. taxation, how foreign-source income is treated can greatly affect business strategies. Many states have recognized the potential of attracting businesses

Andrea Ricci, CPA
Apr 21, 20254 min read


Tax Compliance for International Investments: What is Form 5471 ?
For many U.S. taxpayers, one critical form in this landscape is Form 5471. This form is essential for those with interests in foreign corporations

Andrea Ricci, CPA
Apr 15, 20254 min read


What is FDII in International Tax and Why International Businesses Should Know
In an increasingly global economy, international businesses must navigate complex tax regulations.

Andrea Ricci, CPA
Apr 9, 20254 min read


Investing in Non-U.S. Mutual Funds ? For Your Taxes, It's a PFIC
Investing in international markets can be tempting for U.S. investors seeking diversification and growth opportunities...

Andrea Ricci, CPA
Apr 1, 20254 min read


CFC Taxation: What is Form 5471, Subpart F Income, and GILTI Income
Navigating the waters of foreign tax obligations is critical for U.S. shareholders of controlled foreign corporations (CFCs).

Andrea Ricci, CPA
Apr 1, 20254 min read


Beneficial Ownership Information Reporting (BOIR) Suspended by FinCen in Interim Final Rule
On Friday, FinCen issued an interim final rule that has suspended beneficial ownership information reporting for US companies and citizens.

Andrea Ricci, CPA
Mar 27, 20254 min read


What is Form 1120 F and Who is Required to File One with the IRS ?
Navigating the tax landscape can be daunting, especially for foreign corporations operating in the United States. Form 1120 F is a necessity

Andrea Ricci, CPA
Mar 26, 20254 min read


Understanding FIRPTA: A Foreign Investor's Guide to US Real Property Tax and FIRPTA Withholding
Investing in real estate in the United States is an exciting opportunity for foreign investors.

Andrea Ricci, CPA
Mar 21, 20254 min read
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