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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


Navigating Accounting Requirements for Regulated Investment Funds in the BVI
In the fast-paced world of finance, regulated investment funds in the British Virgin Islands (BVI) have become increasingly popular. This region offers numerous advantages including low taxes and a strong legal system

Andrea Ricci, CPA
Jul 19, 20255 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


How the FASTER Directive is Set to Redefine the Taxation Landscape for Investments in the EU
The new FASTER Directive is set to transform how taxation influences investments in the EU. In this post, we will explore the implications of the FASTER Directive.

Andrea Ricci, CPA
Jun 20, 20254 min read


Understanding the Interplay Between Incoterms and Tariffs in International Trade
Two significant components the international trade and tax environment are Incoterms and tariffs.

Andrea Ricci, CPA
Jun 15, 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


FATCA and the Principality of Monaco: U.S. International Tax Reporting for Banks
The Foreign Account Tax Compliance Act (FATCA) has transformed international tax reporting. Its effects stretch far beyond the United States, significantly impacting global finance. One key region affected by these regulations is the Principality of Monaco.

Andrea Ricci, CPA
May 19, 20254 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


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


Understanding FATCA and CRS: Navigating the Complexities of Global Tax Compliance
Tax compliance has become a pressing global issue, impacting individuals, businesses, and governments.

Andrea Ricci, CPA
Jan 30, 20255 min read


Untangling International Tax: Navigating the Complexities for Remote Businesses
The surge in remote work has revolutionized how businesses operate across borders, offering access to a vast talent pool and new markets

Andrea Ricci, CPA
Dec 10, 20245 min read


The Impact of Import Tariffs: A Comprehensive Editorial Analysis
Import tariffs have captured attention worldwide, stirring debates among economists, policymakers, and business owners alike. These...

Andrea Ricci, CPA
Nov 12, 20244 min read


Unraveling the Complexity of Italian Corporate Income Tax: A Comprehensive Overview
Understanding the complexities of the Italian corporate income tax system is essential for local businesses and international corporations p

Andrea Ricci, CPA
Nov 6, 20244 min read


Understanding Subpart F Income: Uncovering the Complexities of International Taxation
In today's interconnected world, multinational corporations face the challenge of navigating complicated tax laws. One area that often...

Andrea Ricci, CPA
Nov 6, 20244 min read


Decoding Tax Residency: Essential Guide for Nonresident Taxpayers
Understanding tax residency can feel like navigating a complicated maze, especially for nonresident taxpayers.

Andrea Ricci, CPA
Nov 3, 20245 min read


Unraveling the Complexities of Taxation for Broadcasting Income: A Professional Guide
Navigating the world of broadcasting income taxation can feel like a daunting task. Whether you are a seasoned broadcaster or new to the ind

Andrea Ricci, CPA
Oct 30, 20244 min read
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