Tiered by design
A foreign parent owns a U.S. blocker that owns the operating company — each layer absorbing a distinct category of exposure.
Engineered Cross-Border Tax Architecture
Sovereign capital.
Engineered jurisdiction.
Gulzari Global designs the corporate, tax, and treaty architecture that lets non-U.S. residents operate inside the United States deliberately — rather than discovering automatic 30% withholding, a $25,000 Form 5472 penalty, or an unintended taxable presence after the fact.
Personal tax
Business tax
Global & cross-border tax
Jurisdictions We Work Across36 jurisdictions
§01Practice Architecture
Three pillars. One coherent dossier.
Each pillar resolves a discrete category of cross-border exposure. Together they form one structure, built to hold up if the IRS looks at it.
§02Exposure Surface
Six ways the structure quietly fails.
Most foreign-owned U.S. entities carry dormant exposure they never see — until a notice arrives. We surface the vectors before they trigger.
Run full exposure scan§03Diagnostic Engine
See what the IRS would be looking at.
A four-step structural diagnostic maps your entity, scale, and footprint to a live risk read — in under ninety seconds, before a single call is booked.
gulzari://cross-border-structure-diagnostic
Step 2 / 4 · Core Metric ScalingTry it
$0$1M+$10M+
▸ Current asset target · $2.4M
▸ Live exposure read
> run exposure.scan --scale=$2.4M
WARNING Foreign-owned single-member LLC detected.
→ Form 5472 filing obligation triggered · $25,000 exposure
→ 30% FDAP withholding active on U.S.-source revenue
→ No treaty position on file (W-8BEN-E absent)
→ Established scale · structure drives the tax bill
RECOMMENDATION Multi-tier blocker restructure
preview only · the live terminal reads your actual structure
─ The Network ─
Capital moves across borders. So should its architecture.
Not every jurisdiction holds an income tax treaty with the United States. The structure has to account for the ones that do, and for what the rest leave exposed at the border.
W-8BEN-E
Withholding rules
Establishes the treaty claim with the payor, before the payment is made.
Form 8833
Treaty position disclosure
Discloses the treaty-based return position the filing actually relies on.
Form 5472
Foreign-owner disclosure
Reports related-party transactions for a foreign-owned U.S. entity.
§04Operating Mandate
Three costs to avoid. One rate worth having.
Avoid30% withholding
30%
Withheld automatically on U.S.-source payments to a foreign person. Where a treaty applies and the claim is documented before the payment is made, the rate can be reduced.
AvoidForm 5472 penalties
$25,000
The minimum penalty for each year a foreign-owned U.S. company does not file Form 5472, plus a further $25,000 for every 30 days it stays unfiled after an IRS notice.
AdvantageU.S. corporate tax rate
21%
One flat federal rate on corporate profits, below the combined corporate rates of many European countries. Deductions are allowed only where a true and accurate return is filed.
Avoid30% branch profits tax
30%
An extra tax on a foreign company's U.S. branch profits, charged on top of the corporate tax. Operating through a U.S. corporation instead of a branch is how it is designed around; treaty rates vary.
Rates and penalties set by U.S. tax law · Not results from any engagement
Engineering Premise
The IRS is not the adversary. Unstructured exposure is. Every Gulzari Global engagement begins with the same first principle: nothing happens by accident.
We surface the silent triggers — automatic withholding, dormant 5472 obligations, accidental permanent establishment — and replace them with a structure that the founder, the bank, and the auditor can all read in five minutes.
§05The Architecture
One structure. Every exposure, isolated.
We don't patch a flawed entity — we engineer the stack that makes Effectively Connected Income, withholding, and a taxable U.S. presence decisions rather than accidents.
Exposure contained
A blocker is used so U.S. business income is taxed at the corporate level, rather than reaching the parent and the owner directly.
Capital flows clean
Treaty-protected dividends move up; transfer pricing rules govern what moves down.
Ali Gulzari · CPA, EA · Principal
§06Engagement Standard
By acceptance. Not by application.
Gulzari Global is a selective, tax-specialised practice. We take on a deliberately limited roster of high-performing clients.
Tax specialists
Gulzari Global is a firm of U.S. Certified Public Accountants focused on tax: personal, business, and cross-border. Filing and advisory are the core of the work, planned a year ahead rather than reconstructed after it. Where a matter needs legal counsel, we coordinate directly with your attorneys.
Reviewed, then accepted
We operate on a review-and-accept basis. Every prospective engagement is reviewed before we take it on, and we accept a limited number of clients each quarter — so every structure receives the depth it demands.
Built for high performers
The work suits businesses with real cross-border activity rather than a first idea. The diagnostic establishes fit before a conversation is ever booked — your time and ours, respected from the first step.
U.S. Certified Public Accountants · Tax specialists · Engagement by acceptance
§07Who we work with
Built for inbound. Open to everyone with a U.S. return.
The practice is built around people and companies coming into the United States. If you are a U.S. citizen or a U.S. company, the answer is also yes.
We do not run payroll or keep books. Those, and the other few things we refer out, are listed on the questions page.
Read the full questions page- Focus
Non-U.S. residents
Founders, investors, and families outside the United States with U.S. income, property, or a U.S. company to report.
- Focus
Foreign-owned U.S. companies
LLCs and corporations owned from abroad: Form 5472, withholding, treaty positions, and the annual returns that keep the company in good standing.
- Yes
U.S. citizens, at home or abroad
Personal returns, FBAR, foreign tax credits, and streamlined filing for Americans overseas.
- Yes
U.S. businesses
Business returns and tax planning for U.S. companies, including those starting to sell, hire, or invest across a border.
Where the practice works
36 jurisdictions
From Kissimmee, Florida
§08Office of Ali Gulzari
The structure is the part nobody checks.
Ali Gulzari built the practice after a decade watching foreign founders pour millions into the U.S. market through structures nobody had checked before they were used. Single-member LLCs operating without Form 5472. Pass-through profits routed through founders' personal accounts. SaaS revenue treated as ECI by accident.
Each one carrying a $25,000 minimum penalty. Each one visible in advance, had anyone looked.
“The structure is the strategy. Everything downstream — bank accounts, processors, cap tables, treaty positions — only works if the architecture beneath them is correct from day one.”
§09Client record
Rated 5.0 on Google.
Reviews are left on Google and Yelp, where the firm cannot edit them. Every quote on this site links back to the listing it was written on.
Read every reviewYelp · September 2025
“Ali Gulzari, CPA, EA is hands down one of the best accountants I've ever worked with. He recently helped my daughter with urgent international tax forms and certificates that required immediate attention and a very fast turnaround. Not only did he deliver flawlessly under pressure, but he also brought incredible clarity and confidence to a stressful situation…”
Google · April 2026
“I've been using Gulzari CPA for our company's tax returns and couldn't be happier. They are incredibly fast and efficient, making a complex process feel seamless. What I appreciate most is their ability to react to changes on the fly as our business evolves. Highly recommended for any business owner looking for a pro-active partner!”
Sent to the firm
“We had a complex international company for which Ali did our returns. We found him to be an excellent partner in this endeavor. Ali is responsive, knowledgeable, and a pleasure to work with. I highly recommend him for your accounting needs.”
§10Recent Dossiers
The cross-border canon.
Engineered strategy guides, published and cross-linked. Each one targets a specific exposure category, with executable next steps.
─ Begin Your Diagnostic ─
Four steps. Four minutes.
A complete exposure map.
The Diagnostic Terminal maps the dormant triggers in your current structure — from $25,000 Form 5472 penalties to accidental ECI exposure — and produces a ranked remediation outline before you book a consultation.
No upload required · Nothing is sent until you confirm it on the final step