In the increasingly competitive online-gaming industry, choosing the right licensing jurisdiction can dramatically influence your business model, operating costs, and long-term growth strategy. Two jurisdictions that frequently attract the attention of emerging operators are Rota iGaming  (Commonwealth of the Northern Mariana Islands) and Gibraltar iGaming  (United Kingdom overseas territory). Although both offer pathways to operate legally and to interface with payment providers, the regulatory, tax, and reputational frameworks behind them differ substantially. This article provides a clear comparison to help founders, gaming investors, and platform providers understand which jurisdiction better aligns with their strategic needs. Rota IGaming License vs. Gibraltar iGaming License Regulatory Environment & Legal Framework Rota iGaming Rota (CNMI) offers a unique regulatory environment rooted in U.S. federal oversight combined with local autonomy. Online gaming is regulated through the Rota Casino Gaming Commission, and unlike most U.S. jurisdictions, Rota explicitly permits certain forms of online wagering, including skill-based games and eSports-related betting.Operators often appreciate the flexible and business-friendly nature of the Rota iGaming  framework, which is designed to promote innovation, attract international operators, and encourage economic development on the island. However, it is critical to note that a Rota license does not permit accepting wagers from players physically located in U.S. states , due to federal restrictions such as the Wire Act. The license is instead positioned for international markets . Gibraltar iGaming Gibraltar has one of the oldest and most respected regulatory regimes in the global online-gaming industry. The government maintains a strict selection process, often targeting well-capitalized and established operators. Compliance expectations are high: operators must demonstrate robust internal controls, AML/CFT frameworks, responsible-gaming policies, and the financial capability to sustain large-scale operations. The Gibraltar iGaming  framework is widely recognized by banks, PSPs, and tier-one affiliates, making it one of the strongest reputational licenses available. Taxation & Operating Costs Rota iGaming Rota’s tax environment is arguably one of its greatest advantages.The CNMI operates largely outside the U.S. federal income-tax system, and Rota does not impose a corporate income tax on offshore gaming revenue. This results in significantly lower operating costs , making it attractive for start-ups, mid-size operators, and platforms focusing on niche gaming verticals such as eSports or skill games. Additionally, licensing fees and ongoing compliance costs are generally modest when compared to major European jurisdictions. Gibraltar iGaming Gibraltar offers a competitive low-tax regime, with a 12.5% corporate tax rate and a favorable approach to cross-border gaming revenue.However, the cost of maintaining a Gibraltar iGaming  license is considerably higher. Operators must establish a real economic presence in Gibraltar, hire local staff, and maintain dedicated office space. Annual regulatory fees and compliance expenses can also be substantial. Gibraltar tends to attract larger operators who require top-tier reputational standing and are prepared to invest in a fully operational base. Banking, PSP Access & Industry Reputation Rota iGaming Over the last few years, Rota iGaming  has gained traction, particularly among PSPs serving emerging gaming markets. While not as universally recognized as Gibraltar, the jurisdiction is increasingly accepted by mid-tier payment processors, especially for international traffic and alternative gaming formats. For operators with a lean structure or innovative gaming models, Rota strikes a balance between compliance credibility and administrative flexibility. Gibraltar iGaming Gibraltar remains one of the most reputable jurisdictions worldwide.Banks, PSPs, and enterprise-level partners typically treat Gibraltar-licensed operators as part of the “premium” regulatory tier. This reputation translates into easier PSP onboarding, smoother banking relationships, and access to higher-value affiliate networks. For operators seeking maximum credibility in regulated European markets, Gibraltar is often the gold standard. Speed & Complexity of Licensing Rota iGaming Rota offers faster processing times  and a more streamlined application process. For operators aiming to go live quickly, this can be a decisive advantage. The regulatory body is smaller and more accessible, allowing for direct communication and tailored clarifications. Gibraltar iGaming The application process in Gibraltar is extensive, highly detailed, and selective.Only operators with strong financials, proven management teams, and comprehensive compliance structures will be approved. Licensing often requires several months of preparation and regulatory engagement. Which License Should You Choose? Choose Rota iGaming if you want: Low operating and licensing costs A flexible environment for innovative gaming models (eSports, skill games, peer-to-peer wagering) A faster licensing timeline A tax-efficient jurisdiction targeting international (non-U.S.) players Choose Gibraltar iGaming if you want: A world-class, highly reputable license Stronger acceptance by major PSPs, banks, and affiliates Direct access to European regulated markets The operational infrastructure and budget to meet stringent compliance standards Conclusion The Rota iGaming  license and the Gibraltar iGaming  license serve two very different profiles of operators. Rota offers agility, tax efficiency, and accessibility—ideal for innovative and high-growth online-gaming businesses. Gibraltar offers prestige, institutional credibility, and a mature regulatory framework tailored to well-established operators. Understanding your long-term business goals, target markets, and operational capacity is essential in determining which jurisdiction is the best fit. If you are evaluating whether the Rota iGaming  license or the Gibraltar iGaming  license is the right fit for your gaming venture, professional guidance can save you time, money, and costly regulatory mistakes. Andrea Ricci, CPA (Washington State License n. 57269) , founder of Tradepass International Tax LLC , specializes in international tax structuring, U.S.–facing compliance, and gaming-licensing advisory for operators worldwide. Whether you need assistance designing a tax-efficient corporate structure, understanding cross-border regulatory obligations, or navigating the licensing requirements of Rota, Gibraltar, or other global jurisdictions, I am here to help. Get in touch with me to gain more insights on the importance of a global iGaming license for your business.

Gambling is a popular activity worldwide, often associated with excitement and the possibility of winning money or prizes. Yet, many people do not fully understand what gambling truly involves or why it requires strict regulation through licenses. This post breaks down the core elements that define gambling: consideration , the existence of a game of chance , and the reward . It also explains why obtaining a gambling license or an igaming license is essential for anyone operating in this space. Roulette wheel with betting chips, illustrating the chance and reward elements in gambling What Defines Gambling? At its core, gambling involves risking something of value, usually money, on an event with an uncertain outcome. The goal is to win a prize or reward, which can also be monetary or non-monetary. To understand gambling fully, it’s important to look at its three key components: 1. Consideration Consideration means that the player must stake something of value to participate. This is typically money, but it can also be other valuables or tokens. Without consideration, the activity does not qualify as gambling. For example: Buying a lottery ticket for a chance to win a jackpot involves paying money upfront. Placing a bet on a sports game requires risking a certain amount of cash. Consideration is what makes gambling different from free games or contests where no purchase or stake is required. 2. Existence of a Game of Chance A game of chance means the outcome depends largely on luck rather than skill. While some games mix skill and chance, the element of randomness must be significant for the activity to be classified as gambling. Examples include: Slot machines, where the result is determined by a random number generator. Roulette wheels, where the ball lands on a random number. Lottery draws, where numbers are picked randomly. Games purely based on skill, like chess or poker played without betting, do not fall under gambling. However, poker with betting is considered gambling because of the money at stake and the chance element in card distribution. 3. Reward The reward is what the player hopes to win by participating. This can be money, prizes, or other benefits. The reward must be something of value and is usually proportional to the risk taken. For example: Winning a cash prize in a casino game. Receiving a jackpot in an online lottery. Earning points redeemable for goods in some gaming platforms. Without a potential reward, the activity would not motivate players to risk their consideration, and thus it would not be gambling. Why You Need a Gambling License Operating gambling activities without a license is illegal in most countries. A gambling license or igaming license is a legal authorization that allows businesses to offer gambling services. Here are the main reasons why such licenses are necessary: Protecting Players Licensing authorities enforce rules that protect players from fraud, unfair practices, and addiction risks. Licensed operators must: Use certified random number generators to ensure fair play. Provide clear terms and conditions. Offer responsible gambling tools like self-exclusion and deposit limits. This protection builds trust and ensures players have a safe experience. Legal Compliance Governments regulate gambling to control its social impact and generate tax revenue. A gambling license ensures that operators comply with: Local laws and regulations. Anti-money laundering policies. Age restrictions to prevent underage gambling. Without a license, operators risk heavy fines, legal action, and closure. Market Access and Reputation Holding a gaming license allows operators to enter regulated markets legally. Many countries require a valid license for online casinos or sportsbooks to operate within their borders. Additionally, a license enhances the operator’s reputation, attracting more players who seek trustworthy platforms. Examples of Licensing Authorities Malta Gaming Authority (MGA) United Kingdom Gambling Commission (UKGC) Gibraltar Regulatory Authority Curacao eGaming Each authority has its own standards and requirements, but all aim to maintain integrity in gambling. The Role of an iGaming License in Online Gambling The rise of online gambling has made the igaming license especially important. Online platforms offer casino games, sports betting, poker, and lotteries accessible worldwide. Because of the digital nature, regulation is crucial to: Verify the identity of players. Prevent fraud and hacking. Ensure fair software and payout percentages. An igaming license confirms that an online operator meets these standards, providing a secure environment for players. Practical Examples of Gambling and Licensing A local casino must obtain a gambling license from its country’s regulatory body before opening doors. This license ensures the casino follows safety and fairness rules. An online sportsbook needs an igaming license to accept bets legally and protect customer funds. A lottery company must have a gaming license to sell tickets and distribute prizes lawfully. Without these licenses, operators cannot legally offer gambling services, and players risk losing money to unregulated and unsafe platforms. Summary Gambling means risking something of value—usually money—on an outcome that is uncertain, with the hope of winning a reward. Legally and practically, three elements must be present for an activity to qualify as gambling: consideration  (the player pays or stakes something to participate), a game of chance  (the result depends largely on luck, even if some skill is involved), and a reward  (a prize or benefit of real value). Because these activities involve money, randomness, and the potential for harm, most countries require operators to hold a gambling or iGaming license . Licensing frameworks are designed to protect players from fraud and unfair games, enforce responsible-gambling measures, and ensure that operators comply with laws on taxation, anti–money laundering, and age restrictions. A valid license also gives operators access to regulated markets and strengthens their reputation with both players and payment providers. Authorities such as the Malta Gaming Authority, the UK Gambling Commission, Curacao eGaming, and others supervise land-based and online operators to ensure integrity, transparency, and security across the sector. If you are planning to launch or restructure a casino, sportsbook, lottery, or online gaming platform, make sure your licensing, tax, and corporate structure are built correctly from day one. Andrea Ricci, CPA , assists non-U.S. entrepreneurs and iGaming operators with: Choosing the right gambling / iGaming license jurisdiction Designing compliant, tax-efficient international structures Coordinating with local counsel, platforms, PSPs, and regulators Ongoing U.S. and cross-border tax reporting and advisory Reach out to Andrea Ricci, CPA – Tradepass International Tax LLC  to discuss your project and ensure your gambling or iGaming business is properly licensed, compliant, and ready to scale globally. Get in touch with Andrea Ricci, CPA  to receive end-to-end advisory and iGaming compliance support for starting your online casino and securing your Costa Rica  or Rota  casino license .

Costa Rica crypto casino with a Rota iGaming license If you already run (or are planning to run) a crypto casino out of Costa Rica, you probably like two things about that setup: Operational flexibility A relatively light-touch local framework But you also know the downsides: Costa Rica doesn’t issue a true gambling  license, many payment providers and banks treat “Costa Rica-only” licenses with suspicion, and regulators are watching crypto gambling more closely every year. This is where pairing your Costa Rica structure with a Rota iGaming sub-license under Rota Blue Inc.  starts to look very strategic. Rota is part of the Commonwealth of the Northern Mariana Islands (CNMI) , a U.S. Territory. Under the Rota Casino Act of 2007 , amended in 2024 to legalize online casino gambling, Rota Blue holds a Master License and can grant sub-licenses to offshore operators, including crypto casinos. For a Costa Rica-based crypto casino, this combination can give you: No Rota gross gaming revenue (GGR) tax or local surtaxes No CNMI corporate income tax exposure (if you stay “offshore”) Access to a U.S. Territory financial environment with stronger banking and PSP credibility Let’s unpack what that actually means in practice. 1. No Rota GGR Tax or Local Surtaxes for Costa Rica Crypto Casinos Under the Rota Blue framework, the tax treatment depends on where your operating company sits : Local CNMI presence  (CNMI company, staff, etc.): 10% GGR tax 21% CNMI corporate income tax 1% Business Gross Revenue Tax (BGRT) Offshore operator  (e.g., your Costa Rica entity, no CNMI company): 0% local tax  – no GGR, no CNMI corporate tax, no BGRT For a Costa Rica crypto casino, this is the sweet spot: You keep your operational base in Costa Rica  (staff, hosting, management). You obtain a Rota sub-license  via Rota Blue, but do not create a CNMI entity . Under the Rota Blue factsheet, an operator in that “offshore” position has no Rota-level tax obligations at all . So you effectively get: The regulatory badge  of operating “under a U.S. Territory regime”, and No Rota GGR or local surtax cost  as long as you avoid local CNMI presence. For a crypto casino working with tight margins and volatile token economics, avoiding a 10% GGR wedge plus a turnover tax is a very material advantage. 2. Outside the Scope of CNMI Corporate Income Tax (If You Stay Offshore) The same logic applies to CNMI corporate income tax . Rota Blue’s factsheet makes a clear distinction: only operators with a local presence in CNMI  are subject to the 21% corporate income tax ; offshore operators have “no tax (0%)”  at CNMI level. For a Costa Rica crypto casino, that means: Your tax residency  and corporate taxation remain anchored where your entity is actually formed (e.g., Costa Rica), not in Rota. The Rota sub-license is a regulatory overlay , not a tax anchor. You can structure your revenue recognition, tokenomics and profit repatriation  under Costa Rica’s rules (and any other jurisdictions in your holding chain), without CNMI trying to tax your gaming profits – as long as you stay out of “local presence” territory. In other words, you are: Licensed in a U.S. Territory, but not taxed in that U.S. Territory , provided that your crypto casino remains non-resident and non-established in CNMI. From a planning perspective, that’s unusual: most classic gaming jurisdictions (e.g., Malta, many EU frameworks) tend to combine licensing + tax  in a single package. With Rota, you can decouple  those two aspects and marry them to the Costa Rica base. 3. A Crypto Casino With a Gateway to the U.S. Territory Financial System The third pillar is arguably the most strategic: financial access and credibility. The Rota Master iGaming License framework “presents a potential opportunity for banking access through financial institutions within the U.S. territory,” adding the credibility associated with the U.S. environment. For a Costa Rica crypto casino, this matters in several ways: Better optics with banks and PSPs A lot of traditional banks and payment processors are wary of: Purely “Costa Rica-only” setups; and Purely unlicensed crypto casinos. By holding a Rota sub-license : You operate under a U.S. Territory regulatory umbrella  with a defined gaming law (Rota Casino Act) and a Gaming Commission. Rota Blue License Factsheet You are expected to follow U.S.-style AML/CFT, KYC and responsible gaming standards , because the framework itself is aligned with CNMI regulations, the U.S. Bank Secrecy Act and FATF recommendations. This combination – U.S. Territory law, formal license, documented KYC/AML program – can make you far more acceptable  to: Crypto-friendly banks and EMIs Payment processors and card acquirers OTC desks and liquidity providers that insist on “real” regulation Easier crypto–fiat bridging Many crypto casinos struggle with on-/off-ramp friction : Exchanges don’t like “unregulated gambling” activity. Fiat partners worry about chargebacks, reputational risk and sanctions exposure. A Rota license doesn’t magically solve all of that, but it allows you to say: You are licensed under a U.S. Territory regime ; Your AML/KYC framework is designed to follow U.S./FATF standards ; Your business is supervised by a formal Gaming Commission  (RCGC). For risk committees assessing your file, that’s a completely different story compared with “we’re a Costa Rica data processing company running a crypto casino.” 4. Still Crypto-Friendly: “Crypto Games” Explicitly Covered Rota Blue’s license is particularly compatible with a Costa Rica crypto casino because it explicitly allows crypto games . The following are among permitted activities under a Rota Blue iGaming Sub-License: “slots, live dealer, poker, peer-to-peer, daily fantasy, skill games, esports games, crypto games and other chance and skill” (excluding traditional sports betting). So you can: Keep your crypto-native product  (tokens, house coin, NFTs, etc.). Layer RNG-based games, live dealer and esports  on top of it. Run multiple brands/domains  under one Rota sub-license, subject to RCGC approval, which is ideal if you run separate skins for different markets. 5. How the Costa Rica + Rota Combo Might Look in Practice A simplified structure could look like this: Costa Rica company Holds your operational team, marketing, tech, and crypto infrastructure. Books the gaming revenue and bears the main operating costs. Rota sub-license under Rota Blue Gives your Costa Rica entity the right to operate online casino and crypto games under the Rota Casino Act framework. Rota Blue License Factsheet No CNMI tax, no Rota GGR, no BGRT as long as you have no CNMI entity or presence . Banking / PSP stack Crypto-friendly banks or EMIs (potentially including institutions within U.S. Territory) plus global PSPs more comfortable with a U.S. Territory license and documented AML/KYC. Result: your Costa Rica crypto casino keeps its cost-effective base , but now speaks the language regulators and financial institutions want to hear . 6. Compliance and Limitations You Can’t Ignore A few important caveats: No U.S. market access : Rota Blue’s framework restricts U.S. and U.S. Territory players, OFAC-blacklisted countries, and other prohibited markets. Rota Blue License Factsheet  This is not a backdoor into the U.S. consumer market. Serious KYC/AML expectations : You’ll need robust KYC, AML/CFT, and responsible gaming policies , plus regular reporting (financial, compliance, SARs, etc.). Local law still applies : You must remain compliant with Costa Rican law , the laws of the markets you serve, and any other tax or licensing rules that might apply to your structure. This article is not legal or tax advice . Any operator considering this structure should speak with qualified professionals familiar with Costa Rica, CNMI/Rota and the jurisdictions of your target players . Conclusion: A Powerful Upgrade for Serious Crypto Operators For a Costa Rica crypto casino that wants to move from “gray area” perception to proper, recognized regulation , a Rota sub-license via Rota Blue offers a unique mix: Exclusion from Rota GGR and local surtaxes  for offshore operators Exclusion from CNMI corporate income tax , as long as you avoid CNMI presence Real access to a U.S. Territory regulatory and financial environment , with better optics for banks, PSPs, and institutional partners You keep the agility and cost benefits of Costa Rica, but layer on a U.S. Territory license purpose-built for online and crypto gaming . For crypto casinos that want to scale – and to be taken seriously by regulators, counterparties, and investors – that combination is hard to ignore. Do not hesitate to contact Andrea Ricci, CPA  for tailored guidance on optimizing the financial operations of your Costa Rican iGaming business or online crypto casino. The new Rota global online casino license  is quickly emerging as one of the most reliable and trustworthy regulatory options in the offshore iGaming industry. Get in touch with Tradepass International Tax LLC  to understand the specific advantages of the Rota iGaming License and how it can become a real competitive edge for your Costa Rica–based online crypto casino. Andrea Ricci, CPA provides comprehensive financial and regulatory advisory services to help you maintain full online casino compliance and secure access to reputable PSPs and banking institutions.

Online gaming licenses are crucial for establishing the trustworthiness of gambling sites. They act as a reassurance for players, indicating that they are engaging with a regulated entity. However, the Anjouan Online Gaming License has gained a dubious reputation, leading many to label it a scam. In this article, we will explore the details surrounding the Anjouan Online Gaming License, highlighting its flaws and what they mean for players and operators alike. Just Beware of the Anjouan Online Gambling License... Where is Anjouan? Anjouan is one of the four main islands that make up the Union of the Comoros, a small island nation located in the Indian Ocean between Madagascar and the eastern coast of Africa. Officially known as "Ndzuwani" in the local language, Anjouan is known for its mountainous terrain, lush vegetation, and traditional agriculture, including ylang-ylang and vanilla production. Though geographically small and politically part of a developing country, Anjouan has gained international attention in recent years for its offshore services, particularly its remote gambling license regime. Is Gambling Legal in The Comoros Islands? According to the 2024 Mutual Evaluation Report issued by FATF-GAFI for the Union of the Comoros, gambling is explicitly prohibited under the Comorian Penal Code. It is listed among the activities not permitted by law, confirming its illegal status within the national legal framework. Consequently, the Financial Action Task Force did not conduct any specific AML/CFT assessment related to the gambling sector. This finding is particularly striking given that the Comoros—specifically the island of Anjouan—has gained international attention as an emerging hub for online gambling. The disconnect between national legislation and widely-advertised licensing practices raises serious concerns about regulatory consistency and the credibility of the jurisdiction in the global gaming industry. Who is the Official Authority that Issues the Online Gaming License in Anjouan ? According to various internet sources and professional websites, the official authority responsible for issuing online gambling licenses in Anjouan is the Anjouan Betting and Gaming Board (ABGB) —often referred to as the Anjouan Gaming Authority —under the umbrella of the Anjouan Offshore Financial Authority (AOFA) . According to multiple alerts from the Central Bank of the Comoros , it does not recognize  the Anjouan Offshore Finance Authority (AOFA) or similar island-based entities as legitimate regulators of banking or financial services. The bank has repeatedly warned the public that only it  (together with the ANPI for business registration) is authorized to license offshore banking activities, and it has identified and publicly denounced a number of firms falsely claiming Anjouan-issued financial and banking licenses. In addition, a 2014 statement on its website emphasized that no financial offshore license  has ever been granted by any of the Comoros’ islands, including Anjouan . The Central Bank has taken legal action and issued international warnings to combat these unauthorized offshore activities, underscoring that AOFA’s purported licensing powers are invalid and unenforceable  within the Union of the Comoros legal framework. Although the warning issued by the Central Bank of the Comoros does not specifically address international online gambling, it is nonetheless striking that the same Anjouan Offshore Financial Authority—explicitly disavowed in the context of offshore financial licenses—also appears to serve as the institutional façade for purported government bodies (or service providers) issuing online gambling licenses. This raises serious concerns about the legal foundation and authenticity of such licenses, especially when the national authorities have categorically denied the existence of any legitimate offshore licensing regime within the Union of the Comoros. Player Awareness and Risks Here’s a refined summary of player reviews concerning Anjouan‑licensed casinos: Many players have voiced serious concerns about the legitimacy and effectiveness of Anjouan licenses. A recent Trustpilot thread gave Anjouangaming.com a dismal 2.1 out of 5 rating, with all nine reviewers rating it one star. Common complaints include unresponsive support and non-payment of winnings: “This Casino regulatory will not reply to casino complaints … they have not responded back to me once.”  On discussion boards like Casino Guru, users describe a regulatory body more focused on collecting fees than enforcing rules. One user noted a troubling pattern: “Restricted countries ignored … deposits accepted, but winnings confiscated later … Lack of oversight.”  Overall, player feedback suggests that Anjouan‑licensed casinos offer minimal player protection, lack transparency in dispute resolution, and operate in a regulatory environment that leaves many grievances unresolved.. My Professional Advice? Go for Costa Rica, Instead! While both Costa Rica and Anjouan offer relatively accessible licensing frameworks for online gambling operators, a Costa Rica casino license is generally considered more reputable and reliable than an Anjouan license. Costa Rica has a long-standing presence in the online gaming industry, with many established operators having maintained operations there for decades. Although Costa Rica does not issue formal gambling licenses, it allows gaming companies to operate under a standard corporate structure, provided they do not target Costa Rican residents. This regulatory approach, while light, is transparent and backed by a functioning legal system with greater international credibility. In contrast, the Anjouan license is issued by a local authority disavowed by the national government of Comoros, and is not recognized under national law. Moreover, Anjouan-based regulators have been criticized for poor oversight, lack of dispute resolution mechanisms, and issuing licenses without meaningful due diligence. As a result, operators licensed in Costa Rica often enjoy greater trust among players and affiliates, and face fewer reputational risks than those relying on an Anjouan license. Final Thoughts The Anjouan gambling license is widely viewed as a scam or legally dubious  for several key reasons: Gambling Is Illegal in Comoros : According to the 2024 FATF-GAFI Mutual Evaluation Report, gambling is explicitly prohibited under the Comorian Penal Code , meaning any license issued within the Union of the Comoros—including Anjouan—is not legally grounded. No National Recognition : The Central Bank of the Comoros  has publicly stated that no offshore financial licenses —including those supposedly issued by the Anjouan Offshore Finance Authority (AOFA)—are valid or recognized under national law. False Legitimacy : Entities like the AOFA and Anjouan Gaming Authority claim to act as government agencies, but operate independently  of national institutions and appear to use the name of Anjouan to create a veneer of officialdom . No Regulatory Oversight : There is no meaningful enforcement  or dispute resolution. Player reviews and industry forums are full of complaints about non-payments, ignored customer service requests , and zero accountability . AML/CFT Risks Ignored : The Financial Action Task Force (FATF) did not even assess  the gambling sector in its review of Comoros, given its illegal status—further underlining that these licenses have no regulatory basis . In short, the Anjouan gambling license exploits a legal loophole and the lack of national coordination in Comoros to sell licenses that lack legal authority, regulatory credibility, and consumer protection .

For years, “get a Curaçao license” was almost shorthand for launching an offshore online casino quickly and cheaply. That landscape is changing fast — both because Curaçao is tightening its rules, and because new alternatives are emerging. One of the most interesting newcomers is the Rota Blue iGaming Master License  in the Commonwealth of the Northern Mariana Islands (CNMI), a U.S. Territory. Below is a practical, operator-focused Rota vs. Curaçao comparison between the Rota Sub-Operator License  and the traditional Curaçao casino license  (the classic offshore model that grew out of the master/sub-license system, now being replaced by the new LOK regime). Comparing the Curacao and Rota Casino Gaming Licenses 1. Jurisdiction & regulatory framework: Rota vs. Curaçao Below you can find a Rota vs. Curaçao comparison on the specific features of each online gambling licensing systems: Rota (CNMI, U.S. Territory) Regulator: Rota Casino Gaming Commission (RCGC) . Legal basis: Rota Casino Act of 2007 , amended in 2024 to legalize iGaming. Master license holder: Rota Blue Inc. , which grants B2C and B2B sub-licenses under the Act. Policy anchor: Compliance framework aligned with U.S. federal standards  (Bank Secrecy Act, FATF) on AML/CFT, KYC and responsible gaming. In practice, you are operating under a U.S. Territory regulatory umbrella , which is very different from typical offshore islands. Curaçao (classic offshore model, now transitioning) Historically based on the National Ordinance on Offshore Games of Hazard (NOOGH)  and a master license / sub-license  system, with just four master license holders issuing hundreds of sub-licenses. As of December 24, 2024 , Curaçao has moved to a new framework: the National Ordinance on Games of Chance (LOK) , with a central Curaçao Gaming Authority (CGA)  issuing B2B and B2C licenses directly. The “traditional Curaçao license” people know from the last decade is that light-touch, master-and-sub-license offshore regime . That is being phased out and replaced with a more robust, EU-pressured compliance framework — but the brand perception in the market still reflects that history. 2. License structure & scope of games Below you can find a Rota vs. Curaçao comparison with respect to the different license structures: Rota Blue Sub-Operator License (B2C/B2B) Types : B2C (casino operator) and B2B (platform / game / service provider). Vertical coverage : All major online games except traditional sports betting  — slots, live dealer, poker, peer-to-peer games, daily fantasy, skill games, esports and crypto games. Multi-domain : License covers 1 domain; additional domains can be added (up to 30) with an extra monthly fee per domain. Curaçao License (classic model, now LOK) Historically: single, all-inclusive license  covering almost all forms of remote gambling, including sports betting, under a sub-license obtained from a master license holder. Under the new LOK: B2B and B2C licenses issued directly by the CGA, still broadly covering casino, sports, lotteries, bingo, etc. Key difference: If your business model needs sports betting , Curaçao still has an edge on pure vertical coverage. If you’re primarily focused on casino / RNG / live / esports / crypto , Rota’s limitation on sports is much less of an issue. 3. Taxes & corporate structure Here’s where Rota becomes particularly interesting. Rota – CNMI tax vs. offshore structure Offshore (no CNMI company) No local company required No CNMI tax obligations (0%) Local presence (CNMI-incorporated operator) 10% GGR tax  (territorial level) 21% CNMI corporate income tax 1% Business Gross Revenue Tax (BGRT) Potential tax credit or refund under CNMI tax code So conceptually you have two options: Operate offshore with a Rota license CNMI does not tax you; only your jurisdiction of incorporation / tax residence matters. Useful if you already have a tax-optimised corporate structure elsewhere. Incorporate in CNMI  and run the casino from there You plug into a U.S. Territory tax system with clear statutory rates (10% GGR + 21% corporate + 1% BGRT), potentially attractive for operators who want a fully “onshore” U.S. Territory footprint. Curaçao – consistently low profit tax Curaçao has long attracted operators with a very low corporate income tax , typically around 2% on net profits , plus 0% gaming tax and no VAT  for licensed online operators. Under both the older master-license system and the newer LOK framework: You normally incorporate a Curaçao entity , often in an e-zone structure. That entity pays ~2% CIT on gaming profits, but no separate GGR tax , no VAT and no withholding tax on dividends to non-residents. Tax comparison in one line: Rota:  CNMI can be 0% (offshore)  or 10% GGR + 21% CIT + 1% BGRT  if you choose a CNMI company. Curaçao:  typically 2% CIT on net profits, no GGR tax, no VAT , but you must base a company there and meet local substance requirements. From a pure tax-rate perspective, our Rota vs. Curaçao comparison shows that Curaçao remains one of the world’s cheapest “semi-regulated” options. Rota’s competitive angle is that CNMI does not insist on taxing you at all if your structure is offshore — but then your chosen  jurisdiction becomes the real tax driver. 4. Fees & total cost of ownership Here's a Rota vs. Curaçao comparison with respect to total cost of ownership of an online casino license in each of the two jurisdictions: B2C license One-time initial fee: USD 20,000 Monthly fee: USD 3,000  (license covers 1 domain) B2B license Monthly fee: USD 450  (paid annually) Additional domains USD 250/month per domain , max 30 domains per license Application fee : USD 1,000  (refundable only if the license is actually issued; no separate DD fee) Typical timeframe: 4–8 weeks  from application to license, assuming a clean file. Curaçao under LOK (indicative figures) Published analyses of the new LOK regime suggest that: B2C operators can expect: Application fee ≈ €4,600 Government/National Treasury fee ≈ €24,500  per year Supervisory fee ≈ €23,000  per year Total recurring annual fees in the €47,000–55,000  range, plus due diligence charges. B2B providers: Application fee ≈ €4,600 Supervisory fee ≈ €24,500  per year There is also a per-domain fee under the new system, whereas historically one sublicense often covered many domains cheaply. Cost takeaway: On headline license fees , Rota B2C is in the same ballpark as a serious Curaçao B2C (depending on FX and package), but Rota B2B is dramatically cheaper  than Curaçao’s new B2B pricing. Under the old  Curacao master-licence model, many operators paid far less per year via resellers, but that low-cost route is being closed by LOK. 5. Compliance, AML & reputation Rota: U.S. standards from day one Full CDD on the company, directors, officers and UBOs . Sanctions & PEP screening, background checks, and a detailed AML/KYC policy consistent with U.S. Bank Secrecy Act and FATF recommendations . Ongoing requirements: Periodic compliance declarations Quarterly and annual financial reports Annual audited financial statements Monthly player funds certifications Immediate reporting of suspicious activity (SARs) and serious incidents In other words, it is built to look and feel like a serious, U.S.-aligned regulatory framework , even though it is targeted at global (non-U.S.) markets. Curaçao: from “light touch” to more robust oversight The traditional Curaçao model gained its popularity precisely because it was perceived as: Fast and relatively cheap Lighter on AML, RG and reporting compared to Malta, UK, Isle of Man etc. That leniency also created reputational problems. Some PSPs and counterparties view a classic Curaçao sublicense as higher-risk  or “minimal regulation”. The LOK reforms are explicitly designed to fix that: Centralised CGA supervision, standardised AML/CFT requirements Stronger responsible gaming rules (e.g. the 2025 Responsible Gaming Policy under LOK) Stricter enforcement powers against non-compliant operators Reputationally , Curaçao is in a transition: moving away from “cheap and easy” towards “more serious but still low-tax”, while Rota starts from a U.S.-territory, compliance-first  position, albeit with less track record and brand recognition. 6. Market reach & PSP / banking access Rota No regional restrictions in the framework itself, but U.S., U.S. territories and OFAC countries are excluded  from targeting. The big angle here is the potential to access banking and PSP relationships in a U.S. Territory , which many operators hope will carry more weight than a classic “Caribbean offshore” license with European or Asian banks. Curaçao Still one of the most widely recognised iGaming licenses  among PSPs, aggregators and software vendors, simply because of its sheer market penetration. However, some tier-1 banks and acquirers do not accept Curaçao-licensed operators, or will only on-board them in very specific structures, due to historic concerns about oversight and grey-market exposure. In short: Curaçao  wins on ecosystem familiarity  (everyone knows it, everyone has a “Curaçao flow”). Rota  is more of a credibility and compliance play : U.S. Territory law, U.S.-style AML, and a potentially cleaner story for PSPs that are wary of the old Caribbean offshore model. 7. Which license makes more sense for which operator? Very simplified: Rota may be a better fit if: You want a license under a U.S. Territory framework  with explicit Bank Secrecy Act / FATF-aligned AML, and you’re willing to live without sports betting. You’re a B2B supplier  (platform, game studio, aggregator) looking for a low-cost license  that still offers strong regulatory credibility. You intend to structure tax planning elsewhere  (e.g. your Rota-licensed operator is incorporated outside CNMI, so CNMI tax is 0% and only your home jurisdiction matters). Curaçao may remain attractive if: You absolutely need sports betting  under the same umbrella license. You want to tap into an existing ecosystem  where most game suppliers, white-label providers and many PSPs already understand the Curaçao framework. You value the 2% corporate tax  model in Curaçao itself and are comfortable with the new LOK compliance requirements. Final thoughts about the Rota Casino License Both Rota and Curaçao are moving in the same broad direction: more structure, more compliance, but still commercially attractive  compared to places like Malta or the UK. Curaçao is evolving from  a traditional “volume offshore” jurisdiction to  a more standardised European-influenced regime. Rota is coming to market already framed as a U.S. Territory product , with a clear pitch: “offshore reach, onshore-style oversight.” As always, this Rota vs. Curaçao comparison is not legal or tax advice . Before choosing a license, you should map your target markets, corporate structure, tax residence and PSP strategy , and then get formal advice tailored to your specific fact pattern. If you are evaluating whether a Rota casino license or a Curaçao license is the right fit for your iGaming project, consider reaching out to Andrea Ricci, CPA , a U.S. Certified Public Accountant (Washington State License No. 57269) and founder of Tradepass International Tax LLC , who focuses on cross-border tax planning and licensing structures for online casinos and gaming service providers. Andrea can help you compare concrete tax outcomes, map your corporate and licensing structure (including CNMI, Curaçao, and other offshore/onshore options), and anticipate issues with banking, PSPs, and reporting. To explore tailored scenarios for your business, you can contact or connect with Andrea Ricci CPA  on LinkedIn and request a free confidential consultation. To find out more about the new Rota Casino License please click here .

If you’re exploring the Rota iGaming license  (sometimes referenced as the Rota online casino license ), here’s the operator-focused tax picture you need—what’s due locally in Rota, what’s due CNMI-wide, how timing works, and how these pieces fit together for effective tax planning around Rota iGaming tax . This article assumes that the iGaming operator is a CNMI-incorporated entity holding a Rota casino license. If, instead, the business is incorporated in an offshore jurisdiction, CNMI tax rules would generally not apply; in that case, the operator would be subject exclusively to the tax regime of its jurisdiction of incorporation or tax residence. The New Rota International iGaming License - Tax Profiles 1) What’s new in Rota Rota’s casino rules were updated in 2024 to expressly cover online operations (websites and internet-accessible apps). In 2025 the Commission granted conditional licenses that include online gaming authority, confirming the regime is currently live. 2) Rota-level taxes and fees (operator) a) Rota Gaming Tax (core gaming levy). Rota imposes 10% of Gross Gaming Revenue (GGR) . GGR is defined as all sums received as winnings minus  all sums paid out as losses (with specific tournament-fee adjustments). Ordinarily this is filed monthly; for online operations, the regulation allows the Commission to require payment at the time of each player deposit . Late-payment penalties accrue at 5% per month (compounded). b) 1% Gross Revenue Surtax. Rota law adds a 1% gross revenue surtax  (separate from the 10% GGR levy) and states the gambling revenue tax is payable monthly  (statute says by the 7th; the regulation says by the 10th—operators typically follow the earlier date when in doubt). c) Website/app license fee. Each approved gaming website or internet-accessible app pays an annual $2,500  license fee to the Commission. Player-location rule (important for tax & compliance):  Online play must exclude users located in any U.S. state or territory outside the CNMI, and the Commission may designate other blocked locations. Build geofencing/KYC around this . 3) CNMI-wide taxes that still apply to Rota operators a) Business Gross Revenue Tax (BGRT). All CNMI businesses owe BGRT on total yearly gross revenue at graduated rates up to 5%  (combined schedule). Gaming businesses file the monthly OS-3105 plus the OS-3105a-1 “Schedule of Gross Revenue for Gaming Activity.”  BGRT paid is available as a non-refundable credit  against CNMI income tax (NMTIT) liability. b) CNMI “mirror” income tax (NMTIT). Corporate income tax mirrors the U.S. Internal Revenue Code and rates; file Form 1120CM  (or applicable form) with the Division of Revenue & Taxation. Credits (including BGRT credit) apply per CNMI rules. c) Winnings/jackpot taxes (player-facing). CNMI law imposes a 30% gaming-machine jackpot tax  in general, but winnings in a licensed casino  are excluded from this machine-jackpot tax. Where applicable, CNMI rules also require withholding on gambling winnings ≥ $1,000. Online casino operators should coordinate with DRT on W-2GCM  reporting for qualifying payouts. 4) Putting it together (typical stack) Rota level:  10% Rota Gaming Tax  on GGR (potentially collected at deposit for online), + 1%  gross revenue surtax. CNMI level:   BGRT  (graduated up to 5%) on gross revenue (use OS-3105 + OS-3105a-1 for gaming), then NMTIT  on net income with available non-refundable credits  (including BGRT). Note on timing: • Rota GGR tax: regulation says by the 10th  of the following month; statute references by the 7th —conservatively target the 7th unless the Commission confirms otherwise. For web gaming , the Commission can require paying the 10% at each deposit  (cash-flow/tax-ops implication). 5) Compliance checklist (operator) Rota Casino/Online License  & annual website fees in place. Monthly Rota tax remittances  (and any deposit-time payments for online). BGRT monthly filings  with OS-3105  + OS-3105a-1 . NMTIT  annual corporate return ( 1120CM  or applicable) and credit claims. Player-location controls  (geofencing/KYC per Rota rules). Winnings reporting/withholding  where applicable (e.g., W-2GCM ). Final takeaways The Rota iGaming tax  backbone is 10% of GGR , plus a 1% gross revenue surtax  at the local level. BGRT + NMTIT  still apply CNMI-wide—with BGRT credit usable against NMTIT. For online , plan cash management for deposit-time tax  collection if the Commission requires it, and implement strict player-location  controls. Launch under the Rota iGaming license—confidently. Work with Andrea Ricci, CPA (WA License 57269 ) , founder of Tradepass International Tax LLC , specializing in international tax strategies, global iGaming taxes , and financial compliance for the Rota online casino license . Contact Andrea Ricci CPA to get free consultation about the new Rota international iGaming license and discover how it compares to other online casino licenses in Anjouan, Costa Rica, Gibraltar or Kahnawake.

Online gambling is changing fast, and it's essential to have regulations that protect everyone involved. The Commonwealth of the Northern Mariana Islands (CNMI) has launched a new iGaming and online casino license, aiming to attract online gambling operators and improve its economy. This post will examine how this new license benefits both operators and players in this US territory. Understanding the CNMI Online Gambling Landscape The CNMI is a group of islands in the Pacific Ocean known for its tourism. The new online casino license aims to diversify its economy by inviting international online gambling operators. By creating a regulated environment, the CNMI not only enhances local economic opportunities but also offers players a secure and fair gaming atmosphere. The CNMI's gambling framework adheres to international standards, ensuring licensed operators maintain transparency and fairness. According to a recent survey, 75% of players are more likely to engage with platforms that have strong regulatory oversight. This trust is critical for retaining customers. Key Features of the CNMI Online Casino License The CNMI online casino license includes several attractive features for potential operators: Regulatory Compliance : The CNMI has established a regulatory setup that meets global best practices. Licensed operators must adhere to strict standards, paving the way for accountability and trust. Tax Incentives : The territory provides competitive tax rates for online gambling businesses, which can lead to higher profitability. For instance, operators might benefit from taxes as low as 5% on gross gaming revenue, enabling them to reinvest in their services and improve player experience. Market Access : With a CNMI online gambling license, operators can reach a growing player base in the US and Asia. The strategic Pacific location makes it easier for operators to connect with the Asian market, which accounts for approximately 50% of global online gaming revenue. Supportive Infrastructure : The CNMI government aims to foster the online gambling industry by offering resources and technical assistance to help operators succeed. Player Protection : This regulatory framework emphasizes player safety, requiring operators to implement responsible gaming measures, such as self-exclusion and deposit limits. This is vital, especially as studies show around 10% of online gamblers may develop harmful behaviors. Advantages of Having an Online Gambling License in a US Territory Enhanced Credibility and Trust One significant advantage of a CNMI online gambling license is the credibility it offers operators. Players feel safer engaging with licensed platforms. A survey indicated that 82% of players prefer operators that are regulated by established authorities. Trust builds loyalty, leading to repeat business and sustained revenue. Legal Protection Licensing under the CNMI grants legal protections to both operators and players. Operators face fewer legal challenges, allowing them to focus on growth. Players also gain peace of mind, knowing they have avenues for recourse if issues arise. Access to a Growing Player Base The online gambling market is on the rise, with a reported annual growth rate of 11.5% projected for the next few years. A CNMI license lets operators tap into this growth, engaging players who seek convenient and accessible gaming solutions. This can result in increased website traffic and higher revenues. Competitive Advantage In a crowded market, having a CNMI online casino license sets operators apart. It serves as a badge of safety that attracts players who prioritize responsible gaming environments over unregulated competitors. Opportunities for Innovation The CNMI's regulatory structure supports innovation. Operators can pursue new gaming technologies, develop tailored payment solutions, and engage players with fresh strategies. A forward-thinking approach can help operators stay relevant in a fast-changing landscape. The Role of Technology in CNMI Online Gambling Technology is crucial in enhancing the player experience in online gambling. The CNMI is embracing this trend through various advancements, including secure payment systems and cutting-edge gaming software. Mobile Gaming With more players using smartphones for gaming, the CNMI’s online casino license encourages operators to create mobile-friendly platforms. For example, data shows that mobile gaming accounts for approximately 60% of all online gambling transactions, showcasing a growing demand. Blockchain and Cryptocurrency These technologies can substantially reshape online gambling. Licensed operators in the CNMI can explore blockchain for secure transactions and cryptocurrencies for privacy, appealing to tech-savvy players. Research indicates that 40% of online gamblers express interest in using cryptocurrencies for their transactions. Challenges and Considerations While the new CNMI online gambling license offers many benefits, operators should also consider some challenges. Regulatory Compliance Maintaining compliance with CNMI regulations is crucial for keeping the license. Operators must frequently invest in audits and reporting to align with regulatory requirements. Market Competition As more operators obtain the CNMI online casino license, competition will likely increase. To stand out, operators must create unique offerings combined with excellent customer service to attract and retain players. Evolving Regulations The online gambling sector frequently changes, with regulations adapting to new challenges. Operators must stay updated and be flexible enough to handle shifts in the regulatory landscape. A Promising Future for Online Gambling Operators The new CNMI iGaming and online casino license opens up opportunities for operators looking to engage in online gambling. With a solid regulatory framework, appealing tax incentives, and access to an expanding player base, the CNMI is establishing itself as a key player in the industry. By seeking a CNMI online gambling license, operators can build their credibility, enjoy legal protections, and leverage innovative technologies to enhance their gaming offerings. As the gambling landscape evolves, the CNMI's commitment to fostering the industry will be instrumental in its ongoing success. A tranquil beach in the CNMI, showcasing the natural beauty of the islands. In summary, the benefits provided by the CNMI online casino license are clear. This new regulatory framework promises a bright future for operators and players in the online gambling space within a US territory. To learn more about this new iGaming and online casino license in CNMI, do not hesitate to get in touch with Tradepass International Tax LLC and to contact Andrea Ricci CPA .

Investing in U.S. Real Estate: A Guide for Foreign Investors 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. This article aims to clarify the tax obligations foreign investors face when entering U.S. real estate partnerships. By the end, you’ll have a clearer understanding to make informed investment decisions. U.S. Real Estate Investment Partnership Understanding U.S. Real Estate Partnerships A real estate partnership allows two or more parties to combine resources for real estate investment. Common structures include limited partnerships (LPs) and limited liability companies (LLCs). For foreign investors, comprehending the specific partnership type is essential, as it can significantly influence tax obligations and liabilities. These partnerships not only widen access to larger investment projects but also come with distinct tax implications that vary based on the partnership’s structure and the investor's residency status. For instance, partnerships often engage in projects exceeding a million dollars, which might be out of reach for individual investors. Identifying Your Tax Residency Status Before diving into tax obligations, it's important to clarify your tax residency status in the U.S. Generally, foreign investors fall into one of two categories for tax purposes: Nonresident Aliens : These individuals do not meet the substantial presence test or lack a green card. Generally, they are taxed only on income earned in the U.S. Resident Aliens : Those who meet the substantial presence test or have a green card are taxed on their global income, similar to U.S. citizens. Determining your residency status is crucial for assessing your tax obligations when investing in U.S. real estate partnerships. Tax Implications for Foreign Investors 1. FIRPTA Overview The Foreign Investment in Real Property Tax Act (FIRPTA) is vital for foreign investors in U.S. real estate. According to FIRPTA, foreign investors are taxed on the sale of U.S. real property interests. For example, if a foreign investor sells their interest in a U.S. partnership, they could face capital gains tax. Under FIRPTA, the buyer generally must withhold 15% of the sales price at closing and remit it to the IRS as a prepayment toward the investor's tax liability. This means if a foreign investor sells a property for $1 million, $150,000 could be withheld for taxes. 2. ECI Income Foreign investors may earn effectively connected income (ECI) from U.S. real estate partnerships. ECI refers to income associated with a trade or business engaged in the U.S. For example, if you own a rental property that generates $100,000 annually in rental income, that amount is considered ECI. Those earning ECI must file a U.S. tax return using Form 1040-NR. This form enables investors to report U.S. income and claim necessary deductions. 3. Tax Treaties Many countries have tax treaties with the U.S. that can alter the tax obligations for foreign investors. Such treaties often provide reduced tax rates or exemptions on certain types of income, including capital gains and rental income. The U.S. has treaties with countries like Canada, the UK, and Australia, enabling reduced tax rates. Therefore, it's wise to examine any relevant treaty to optimize your tax liabilities. Required Filings for Foreign Investors 1. Form 1040-NR As reiterated, foreign investors earning ECI must file Form 1040-NR. This form is vital for reporting income, deductions, and tax liability accurately. Missing or inaccurately completing this form can lead to penalties. 2. FIRPTA Withholding Certificate If you believe your actual tax liability will be lower than the FIRPTA withholding amount, you can apply for a withholding certificate. This certificate allows a reduced withholding based on your estimated tax liability. To obtain this certificate, submit Form 8288-B to the IRS, along with supporting documents. Seeking professional advice can simplify this process. 3. State Tax Considerations In addition to federal tax obligations, foreign investors may face state taxes based on where their property is located. For example, states like California and New York have unique tax laws that could impose additional obligations. Therefore, research the specific tax laws relevant to your investment's state to ensure compliance. Strategies for Effective Tax Planning 1. Seek Professional Guidance Given the intricacies of U.S. tax laws, consulting a tax professional with expertise in international tax can be invaluable. Their guidance can navigate you through FIRPTA, ECI, and state-specific tax obligations, ultimately saving you time and money. 2. Evaluate Partnership Structure The partnership structure can greatly influence your tax liabilities. For instance, investing through a U.S. LLC may present certain tax advantages compared to direct investments in a partnership. An LLC can provide limited liability protection and potential tax benefits, making it an attractive option for many foreign investors. 3. Stay Updated on Tax Changes U.S. tax laws frequently change, which can impact your obligations. Regularly reviewing tax regulations and consulting with professionals can help you stay informed and optimize your investment strategy. Navigating the Complex Tax Landscape Understanding the tax landscape is essential for foreign investors. The U.S. tax system can be intricate, with various regulations and requirements. By familiarizing yourself with these aspects, you can better prepare for your investment journey. 1. Importance of Tax Compliance Tax compliance is crucial for maintaining a good standing with the IRS. Non-compliance can lead to severe penalties and complications in your investment activities. Therefore, it's vital to stay informed about your obligations and ensure timely filings. 2. Utilizing Tax Benefits Foreign investors can take advantage of various tax benefits available under U.S. law. These may include deductions for property depreciation, mortgage interest, and other expenses related to property management. Understanding these benefits can enhance your overall investment returns. 3. Long-Term Investment Strategy When investing in U.S. real estate, consider a long-term strategy. Real estate markets can fluctuate, and having a long-term perspective can help you weather economic downturns. This approach allows you to capitalize on the appreciation of property values over time. Wrapping It Up Investing in U.S. real estate partnerships offers foreign investors a chance to leverage their capital in a thriving market. However, it’s essential to grasp the specific tax requirements involved. From understanding FIRPTA withholding to reporting ECI income, navigating the complexities of U.S. tax laws can be overwhelming. Recognizing your tax residency status, the implications of FIRPTA, and necessary filing requirements will empower you to make informed decisions about your investments. Additionally, working closely with a tax professional and keeping updated on changes in tax law will enhance your investment strategy. By proactively addressing your tax obligations, you’ll be well-equipped to maximize returns on your U.S. real estate investments while avoiding pitfalls. If you are a foreign investor (i.e., a nonresident alien taxpayer) with an interest in a U.S. Real Estate partnership subject to FIRPTA and to U.S. income tax obligations, do not hesitate to get in touch with Tradepass International Tax LLC. As an experienced tax professional, Andrea Ricci CPA can help you comply with complex U.S. income tax requirements for foreign taxpayers and prepare your U.S. income tax return . Get in touch with Andrea Ricci CPA for a price quotation and for tax consultation.

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. This document is essential for ensuring compliance with U.S. tax laws and avoiding significant penalties. In this post, we will explore what Form 5472 entails, who is required to file it, and when it is due. What is Form 5472? Form 5472 is an information return required for foreign-owned U.S. disregarded entities and foreign corporations that engage in business activities in the United States. According to IRS regulations, this form is used to report specified transactions between the reporting entity and related foreign parties. The primary purpose of Form 5472 is to enhance the IRS's ability to monitor the financial activities of foreign-owned businesses, ensuring transparency and adherence to tax laws. For instance, in 2020, the IRS reported imposing penalties totaling over $1.5 million for non-compliance regarding Form 5472, illustrating the financial risks associated with failing to file this form. Who Needs to File Form 5472? Foreign-Owned U.S. Disregarded Entities Foreign-owned U.S. disregarded entities, such as single-member limited liability companies (LLCs) owned by foreign nationals or companies, are required to file Form 5472 if they report transactions during the tax year. For example, if a foreign individual owns an LLC that sells goods in the U.S. and engages in various financial activities, such as loans or payments for services, they must submit Form 5472. Foreign Corporations Foreign corporations that operate a branch in the U.S. or conduct transactions with related domestic parties also need to file this form. To illustrate, a foreign corporation with a U.S. branch that pays royalty fees to its foreign parent company must report those payments on Form 5472. Exceptions to Filing Not all entities are mandated to file Form 5472. For example, if a foreign-owned LLC has not engaged in any reportable transactions within the tax year, it may not need to file the form. However, you should always consult with a tax advisor to verify your specific circumstances. When is Form 5472 Due? Form 5472 typically has the same due date as the entity's income tax return. For businesses following a calendar year, this means the form is due on April 15 of the following year. If the entity’s tax return is extended, the due date for Form 5472 is also pushed back appropriately. Extensions If additional time is needed to complete Form 5472, you can file Form 7004 to request a six-month extension. However, keep in mind that this extension only applies to the filing date and not to any taxes owed. What Transactions Must Be Reported? Form 5472 requires reporting of various transactions between the foreign-owned entity and its related parties. Some examples include: Sales of products or services that exceed $10,000 Loans, including interest and repayment details Payments for using intellectual property, such as patents or trademarks Any other transactions that meet the reporting criteria Accurate record-keeping is essential, as this information helps ensure compliance with IRS regulations. How to Complete Form 5472 While completing Form 5472 may seem challenging, breaking it down into sections can simplify the process. The main parts of the form include: Identification of Reporting Corporation : This section gathers basic information such as the entity's name, address, and Employer Identification Number (EIN). Related Party Information : You will provide details about the foreign owners and any related parties involved in reportable transactions. Transaction Details : This portion requires a detailed account of all transactions that occurred during the tax year, including transaction types and amounts. Signature and Declaration : An authorized individual must sign the form, affirming the accuracy of the provided information. Common Mistakes to Avoid When filling out Form 5472, pay close attention to avoid these frequent errors: Missing the filing deadline Providing inaccurate or incomplete details Neglecting to report all essential transactions Diligently reviewing your form before submission can help you avoid costly mistakes. Penalties for Non-Compliance The IRS enforces strict penalties for failure to file Form 5472 or incorrect submissions. The penalty for not filing can be $25,000 for each year the form is late. If the IRS detects intentional non-compliance, the fines can soar even higher. In 2021, around 10% of foreign-owned entities faced penalties due to missed Form 5472 filings, underscoring the importance of understanding your obligations. Staying Compliant with Form 5472 Understanding Form 5472 and its implications is critical for foreign-owned businesses operating in America. By being aware of who must file it, when to file, and what transactions to report, you can navigate these requirements effectively. If you are uncertain about your filing obligations or require assistance with Form 5472, consider seeking help from a tax professional who specializes in international tax matters. Engaging their expertise can help you avoid hefty penalties and maintain your business's good standing. A close-up view of a tax form with a pen for filling out By understanding the specifics of Form 5472, you will be better equipped to manage your foreign-owned LLC or corporation while ensuring compliance with U.S. tax regulations. Andrea Ricci CPA, as an international tax CPA , can help you in preparing Form 5472 for your foreign-owned limited liability company in the United States (U.S. LLC), ensuring your company remains 100% compliant with IRS requirements and with the tax laws of the United States. Do not hesitate to get in touch with Andrea Ricci CPA to obtain a free consultation on U.S. income tax returns .

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). This blog post will explain what an ITIN is, who needs one, and how to obtain it through a Certifying Acceptance Agent (CAA). W7 ITIN Application through a Certifying Acceptance Agent (CAA) What is an ITIN? An Individual Taxpayer Identification Number (ITIN) is a tax processing number issued by the Internal Revenue Service (IRS). It is designed for individuals who must have a U.S. taxpayer identification number but are not eligible for a Social Security Number (SSN). ITINs serve essential functions, such as allowing individuals to file tax returns and comply with U.S. tax laws. For example, non-resident aliens, their spouses, and dependents without an SSN can report their income and claim tax benefits with an ITIN. Having an ITIN is critical for meeting U.S. tax obligations. Who Needs an ITIN? Several groups may require an ITIN, which includes: Non-resident aliens : Individuals who must file a U.S. tax return. Dependents or spouses : Foreign nationals who are dependents or spouses of U.S. citizens or resident aliens. Approximately 5 million U.S. citizens have foreign spouses, making this a significant category for ITIN need. Ineligible for an SSN : Individuals needing to fulfill tax duties but who do not qualify for an SSN. Recognizing whether you need an ITIN is the first step in the process. The Role of a Certifying Acceptance Agent (CAA) A Certifying Acceptance Agent (CAA) is an authorized individual or entity by the IRS that helps applicants obtain an ITIN. CAAs play a vital role in the application process by verifying your identity and foreign status. Utilizing a CAA can streamline the process of obtaining an ITIN. For instance, a CAA can assist you in accurately completing the necessary forms and gathering required documentation. Their familiarity with IRS requirements often results in fewer delays. Benefits of Using a CAA Choosing to work with a CAA when applying for an ITIN comes with several significant advantages: Expert Guidance : CAAs have a deep understanding of the ITIN application process. This expertise can be crucial in ensuring that your application is filled out correctly. Document Verification : CAAs help confirm your identity and foreign status, both essential for obtaining an ITIN. For instance, they can check that your passport or identification documents meet the IRS criteria. Faster Processing : Applications submitted through CAAs often experience quicker processing times since they ensure that all documentation is complete and accurate from the start. Convenience : Navigating the complexities of tax forms and submissions can be challenging. A CAA simplifies this process, allowing you to focus on other important matters. How to Find a CAA Finding a qualified CAA is crucial for an efficient ITIN application process. Here are steps to guide your search: Search the IRS Website : The IRS lists approved CAAs on its website, ensuring you find certified agents in your area. This resource is commonly used and is known for its reliability. Ask for Recommendations : Reach out to people in your network, especially if they have successfully obtained an ITIN. Personal experiences can provide valuable insights. Check Credentials : Always ensure that the CAA you select is authorized by the IRS and has a proven track record in handling ITIN applications. Read Reviews : Look for testimonials or online reviews to assess the CAA's reliability and effectiveness, helping you make an informed choice. The ITIN Application Process Once you have found a CAA, you can begin the ITIN application process. Follow this step-by-step guide to stay on track: Step 1: Complete Form W-7 The first step is to fill out IRS Form W-7, which is the application for an ITIN. This form requires personal information, including your name, address, and foreign status details. Step 2: Gather Required Documentation You must provide supporting documents for your application, which generally includes: Proof of identity : Such as a passport or national identification card. Proof of foreign status : This could be your visa or birth certificate. Consult with your CAA to determine which documents are appropriate for your situation. Step 3: Submit Your Application After completing Form W-7 and gathering the necessary documents, your CAA will submit your application to the IRS on your behalf. Step 4: Wait for Processing Processing an ITIN application typically takes 6 to 8 weeks . Being patient during this time is crucial. Step 5: Receive Your ITIN Once your application is approved, you will receive your ITIN via mail. This number is vital for meeting your U.S. tax obligations. Common Mistakes to Avoid When applying for an ITIN, be aware of common pitfalls that could complicate the process. Watch out for: Incomplete Forms : Ensure every section of Form W-7 is completed fully. Incomplete information can lead to delays. Incorrect Documentation : Double-check that all provided documents are correct and meet IRS standards. Deciding Not to Use a CAA : Though you can apply independently, using a CAA significantly reduces the chances of making mistakes. Ignoring Deadlines : Stay conscious of tax-related deadlines to avoid unnecessary penalties. Frequently Asked Questions (FAQs) What is the cost of obtaining an ITIN through a CAA? The fees for using a CAA vary based on the agent and the services offered. Discussing costs upfront can prevent any unexpected charges. How long does it take to receive an ITIN? Receiving an ITIN typically takes about 6 to 8 weeks , but timing can differ based on various factors. Can I renew my ITIN? Yes, ITINs expire if they are not used in three consecutive years . Renewing an expired ITIN follows a process similar to the initial application. What should I do if my ITIN application is denied? If denial occurs, the IRS will inform you of the reason. Work with your CAA to resolve the issues and reapply. Final Thoughts Obtaining an ITIN is essential for many non-resident aliens and foreign nationals in the United States. By familiarizing yourself with the ITIN process and the role of a Certifying Acceptance Agent (CAA), you can approach U.S. tax laws more confidently. Whether you are filing taxes for the first time or renewing your ITIN, a CAA's expertise can make the process smoother. If you need an ITIN through a CAA, do not hesitate to get in touch with Andrea Ricci CPA . As a IRS-authorized Certifying Acceptance Agent, and for as low as $250, Andrea Ricci CPA can help you in obtaining an ITIN to meet your U.S. income tax obligations in an economically efficient and fast manner. For most nonresident aliens with business or employment relationships in the United States, an ITIN is required to file a U.S. individual income tax return for nonresidents (Form 1040-NR).

When Congress passed the One Big Beautiful Bill Act  on July 4, 2025, it didn’t just tweak the corporate tax code—it rewrote one of its most strategically important incentives. 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) . How the new FDEI tax regime will help American exporters What Exactly Is the FDEI Deduction? In its simplest form, the FDEI deduction is a permanent, preferential tax rate  for U.S. corporations that generate income from foreign sales of goods and services . It’s designed to encourage American companies to produce, innovate, and export from U.S. soil , rather than shifting operations offshore. The mechanics are now refreshingly straightforward: FDEI Deduction= 33.34%×FDEI This replaces FDII’s tangled formula, which involved calculating deduction-eligible income, applying a foreign sales ratio, and reducing the result by the so-called QBAI offset (which penalized firms with large tangible asset bases in the U.S.). How It Works in Practice Here’s how the deduction applies: Eligible Income : Sales of goods, licenses of software, and provision of services to foreign customers. Exclusions : Gains from selling or transferring intangible property (e.g., patents), and sales of depreciable or amortizable property. Benefit : The deduction effectively lowers the corporate tax rate on qualifying foreign sales to about 14% —compared to the standard 21%. Why OBBBA Changed It The old FDII structure was criticized on two fronts: Complexity  — It required accountants to run a multi-step formula that only a tax department could love. Misaligned Incentives  — The QBAI offset discouraged U.S. investment in tangible assets, directly contradicting the stated goal of bringing production back home. OBBBA’s FDEI regime fixes both. By removing the QBAI penalty, companies can now expand U.S. manufacturing without watching their export tax break shrink. And by locking the deduction rate at 33.34% , Congress removed the uncertainty of the scheduled 2026 cut that would have slashed benefits by nearly half. Winners and Losers The winners are clear: U.S.-based exporters with real production capacity —think aerospace, machinery, semiconductors, and specialized manufacturing. They’ll enjoy a cleaner, more predictable tax incentive that scales with their foreign sales. The losers? Companies whose FDII strategy hinged on shifting intangible property abroad to capture a deduction without much real economic activity in the U.S. That door has now closed. The Bigger Picture FDEI is more than just a tax tweak—it’s a signal. Washington is telling exporters: “Keep your operations, your innovation, and your jobs here—and we’ll reward you when you sell to the world.” Whether this streamlined incentive will drive a manufacturing renaissance remains to be seen. But one thing is certain: FDEI is a cleaner, more transparent play in America’s tax policy arsenal—and it just made exporting from the U.S. more attractive than it’s been in years.

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. Below is a breakdown of the most important changes and their implications. Key GILTI Changes After OBBBA Background: What Was GILTI? GILTI was designed to discourage U.S. corporations from shifting income to low-tax jurisdictions. It imposed a minimum tax  on certain “excess returns” earned by Controlled Foreign Corporations (CFCs), calculated broadly as: GILTI = CFC’s Net Tested Income – 10% of Qualified Business Asset Investment (QBAI) U.S. corporate shareholders could claim a 50% deduction  (Section 250) and a foreign tax credit (FTC)  limited to 80% of foreign taxes paid , but individual shareholders of CFCs had no such relief unless they made a Section 962 election. Key GILTI Changes Under the OBBBA The OBBBA introduced five major changes  to the GILTI regime: 1. Country-by-Country (CBC) GILTI Calculation Under the TCJA, GILTI was calculated on an aggregate  basis—meaning all CFC income and taxes were pooled. This allowed high-tax income to offset low-tax income. The OBBBA eliminated this aggregation. Starting from tax years beginning after December 31, 2025 , GILTI is now computed on a country-by-country basis . This aligns the U.S. with OECD Pillar Two principles , and prevents income from low-tax jurisdictions from being masked by foreign taxes paid elsewhere. Implication:  More U.S. shareholders will owe residual U.S. tax on low-taxed foreign income—even if their global effective foreign tax rate is above the GILTI threshold. 2. Reduced Section 250 Deduction The Section 250 deduction for GILTI was previously 50%  for corporations, effectively reducing the GILTI tax rate from 21% to 10.5%. The OBBBA reduced the deduction to 25% , increasing the effective GILTI rate to 15.75%  (21% × 75%). This brings the U.S. closer to the OECD’s 15% minimum tax  under the global anti-base erosion (GloBE) rules. Implication:  U.S. corporations with foreign subsidiaries will pay more U.S. tax unless foreign taxes paid are sufficient to offset the increased U.S. burden. 3. Full Foreign Tax Credit (FTC) for GILTI The OBBBA increased the allowable foreign tax credit on GILTI from 80% to 100% , although it retained the no carryforward/carryback  rule and introduced separate FTC baskets by country . This change partially offsets the impact of a higher GILTI rate and the shift to CBC methodology. Implication:  U.S. corporations can now use all foreign taxes paid on GILTI income, but must do so on a country-specific basis. 4. Expanded Application of Section 962 Election The OBBBA made permanent improvements to the Section 962 election , which allows individuals to be taxed on GILTI as if they were corporations. Previously, individuals electing 962 could claim the 50% deduction but were often denied FTCs by the IRS (leading to litigation). Under the OBBBA: Individuals electing 962 can now claim FTCs on GILTI income , subject to CBC limitations. The 962 election now also applies to domestic pass-through entities  owning CFCs. Implication:  Individual U.S. shareholders of CFCs (especially in closely held structures) are now better positioned to mitigate GILTI liability. 5. End of the QBAI Exemption The 10% return on QBAI—essentially a carveout for tangible asset returns—was repealed. GILTI now applies to all net tested income , regardless of physical investment in foreign jurisdictions. This aligns GILTI more closely with OECD global minimum tax rules, which do not include a tangible asset exemption. Implication:  U.S. taxpayers with significant manufacturing or tangible foreign assets will see higher GILTI inclusions than under the old regime. Final Thoughts The OBBBA brought GILTI into alignment with evolving global norms—but at the cost of complexity and a higher tax burden for many U.S. taxpayers with foreign operations. The shift to country-by-country calculations, repeal of QBAI, and reduced Section 250 deduction all serve to increase the U.S. tax exposure of multinationals, even as the FTC rules offer some relief. For U.S. taxpayers with international operations—whether large public multinationals or individual shareholders of foreign businesses— proactive planning is essential . Choosing the right entity structure, modeling foreign effective tax rates, and using tools like the Section 962 election are now critical in minimizing GILTI exposure under the post-OBBBA regime.