The questions we are actually asked.

We are tax specialists, and the core of the work is filing and advisory. Most of it is U.S. inbound international tax: the structure, treaty positions, and federal filings that apply when a person or business outside the United States operates inside it. In practice that means choosing and setting up the right U.S. entity, usually a U.S. corporation rather than a foreign company trading here directly, Form 5472 filings, W-8BEN-E and treaty claims, nonresident returns, the substantial presence test, FBAR and FATCA disclosure, and ITIN applications. We also work with U.S. citizens, at home or abroad, and with U.S. companies. The practice is led by Ali Gulzari, a Florida-licensed CPA and IRS Enrolled Agent certified in U.S. international taxation by the AICPA.

No. We do not run payroll, file payroll tax returns, or administer benefits. We have intentionally positioned the practice around high-level tax work, and payroll is not part of it. If you need a payroll provider we will refer you to one.

No. We do not keep books, reconcile accounts, or produce monthly management accounts. Clean books are an input to the work we do, not part of it. We are happy to refer you to a bookkeeper, and we will tell your bookkeeper what we need the records to show.

No. We do not issue audit, review, or compilation opinions on financial statements. If a bank, investor, or regulator requires an audited statement, that is a separate engagement with a firm that performs attest work.

Gulzari CPA LLC is a firm of U.S. Certified Public Accountants. It is not a law firm and does not practice law. No communication with this firm creates an attorney–client relationship. Where legal counsel is required we coordinate with your attorneys.

Not on its own. We do not sell standalone company filings — a registered agent or an online formation service will do that for less than we would charge. We form entities as part of a structure we are advising on, because the value is in deciding what to form, where, and with what ownership and elections, not in the filing itself.

No. We do not manage assets, sell securities or insurance, or give investment advice. We advise on the tax consequences of transactions you and your advisers decide to enter into.

Yes. The focus of this practice is inbound work, meaning non-U.S. persons and foreign-owned businesses with U.S. exposure, but we also work with U.S. citizens, including those living abroad, and with U.S. companies. That covers personal and business returns, FBAR, foreign tax credits, and streamlined filing compliance for Americans overseas. Tell us your situation and we will take it from there.

Yes. There is no citizenship or residency requirement to own a U.S. entity. You do not need a green card, a visa, or a Social Security Number to be an owner. What changes with residency is not whether you may own the company, but which filings the company and you personally are required to make, and how the income is taxed.

Neither is better in the abstract; they solve different problems. A Wyoming LLC is cheaper to maintain, has strong privacy protections, and passes income through to the owner, which for a non-resident can mean no U.S. entity-level tax if no income is effectively connected to a U.S. trade or business. A Delaware C-Corp pays tax at the entity level but is what institutional investors expect, supports stock option plans and preferred rounds, and can block U.S. filing obligations from reaching the foreign owner personally. If you intend to raise venture capital, the answer is usually Delaware. If you are running a profitable business you own outright, it is usually not.

Not necessarily wrong, but frequently incomplete. Those services form the entity and obtain the EIN correctly. What they do not do is file the annual federal information returns a foreign-owned entity then owes, and many owners do not learn that Form 5472 exists until a penalty notice arrives. If you formed a U.S. entity through a service and have not filed anything federal since, that is worth checking before the next filing deadline rather than after.

You do not need either to own the company. The company itself needs an EIN, which can be obtained without a U.S. taxpayer identification number for the owner. You will need an ITIN if you personally have a U.S. filing obligation — for example if you must file a Form 1040-NR, claim a treaty benefit on a personal return, or are named on certain filings. We prepare ITIN applications where one is required.

You need a registered agent with a physical address in the state of formation, which is a paid service, and a mailing address for correspondence. You do not need an office. Be careful with the opposite problem: renting real space, holding inventory, or having people work for you in the United States can create the U.S. presence that triggers tax, so a U.S. footprint should be a deliberate decision rather than a convenience.

Form 5472 is an information return about transactions between a U.S. business and its foreign owners or related parties. You have to file it if your U.S. corporation is at least 25% foreign-owned, or if you own a U.S. single-member LLC that is treated as a disregarded entity and you are not a U.S. person. A foreign-owned single-member LLC files Form 5472 attached to a pro-forma Form 1120, even when the LLC had no profit. Reportable transactions include money you put into the company and money you take out, not just sales.

The penalty is $25,000 per form per year, and it applies for filing late, filing incomplete, or not filing at all. A second $25,000 can be charged for continued failure after the IRS gives notice. There is a further consequence people miss: while a required information return is outstanding, the time limit the IRS has to assess tax on that year does not run out. An unfiled year stays open indefinitely rather than closing on the normal schedule.

Usually yes. The Form 5472 obligation for a foreign-owned single-member LLC is triggered by reportable transactions with related parties, and forming the company, funding the bank account, and paying expenses from owner funds are themselves reportable transactions. A dormant year with a bank account and a registered agent fee is rarely a year with nothing to report. Filing a return showing no profit costs very little; not filing one costs $25,000.

For a calendar-year foreign-owned single-member LLC, the pro-forma Form 1120 with Form 5472 is due 15 April, with an extension available to 15 October. A foreign corporation filing Form 1120-F generally has a later date, and the deadline differs depending on whether it has a U.S. office. FBAR is due 15 April with an automatic extension to 15 October. Dates shift when they fall on a weekend or holiday. Confirm the specific dates for your entity and year rather than working from a general rule.

It is a solvable problem and it is better solved before the IRS raises it. There are established procedures for coming into compliance, and which one fits depends on what was missed, for how long, and whether the failure was wilful. What we would want to look at first is the size of the exposure and whether penalty relief is realistically available on the facts. Nobody can promise a particular outcome, and you should be sceptical of anyone who does.

FBAR is a report of foreign bank and financial accounts, filed with FinCEN rather than the IRS. It applies to U.S. persons — which includes U.S. citizens, green card holders, and people who meet the substantial presence test — whose foreign accounts together exceeded $10,000 at any point in the year, even for a single day. It is a common trap for someone who has just become a U.S. tax resident and still holds accounts at home.

If you are not a citizen or green card holder, it comes down to how many days you spent in the United States. The substantial presence test counts every day of the current year, one third of the days in the previous year, and one sixth of the days in the year before that. If the total reaches 183 and you were present at least 31 days in the current year, you are treated as a U.S. tax resident and taxed on your worldwide income. Certain days do not count, and there are exceptions that can override the result even when the arithmetic says you qualify.

Not necessarily. If you were present fewer than 183 days in the current year, kept a tax home in another country, and had a closer connection to that country than to the United States, you may be able to claim the closer connection exception on Form 8840. Separately, if you are resident in a country with a U.S. tax treaty, the treaty tie-breaker rules may resolve residency in favour of that country. Both are claims you make, with a filing, and both can be lost by not making them on time.

Yes. A U.S. tax resident is taxed on worldwide income, not just U.S. income, and also picks up foreign account and asset reporting obligations such as FBAR and FATCA. This is the single most expensive surprise in inbound tax, and it is usually caused by day counting rather than by any deliberate decision to move.

It depends on whether the income is connected to a U.S. trade or business. Income effectively connected to a U.S. trade or business is taxed at graduated rates after expenses, and is filed on a return. Passive U.S.-source income such as certain interest, dividends and royalties is generally taxed by withholding at a flat 30% at source, which a treaty may reduce. Getting this classification right is most of the work, because the two regimes produce very different numbers on the same revenue.

It is one of the most contested questions in this area and the honest answer is that it depends and that the analysis is not settled. Holding inventory in U.S. warehouses and having it picked, packed and shipped domestically is a real U.S. footprint, and the IRS has taken the position in guidance that it can amount to a U.S. trade or business. Where a tax treaty applies, the permanent establishment article may reach a different answer than the domestic rules would. Anyone who tells you the answer is obviously no, or obviously yes, has not looked at your facts.

Having U.S. customers is not by itself enough. What matters is whether you have people, property, or dependent agents in the United States, and how the income is characterised — sale of a service, licence of software, or something else, which can change both the sourcing and the withholding treatment. A founder working entirely from abroad with no U.S. staff and no U.S. servers is in a very different position from one who has hired a U.S. employee.

It can be. A contractor who works only for you, follows your instructions, and habitually concludes contracts on your behalf may be treated as a dependent agent, which can create a taxable U.S. presence for your business. A genuinely independent provider serving multiple clients generally does not. The label on the agreement matters far less than how the relationship actually runs.

Using a U.S. payment processor does not, on its own, make your income U.S.-source or create a U.S. trade or business. What it does create is a U.S. information trail and, in some cases, withholding on payouts if your tax documentation is missing or wrong. If a processor is withholding from your payouts, the usual cause is a missing or incorrectly completed W-8BEN-E rather than a substantive tax liability.

Either send a short message describing the structure you have and what you are trying to work out, or run the structural diagnostic on this site, which maps your entity, jurisdiction and footprint to the exposure categories we work in and gives you an outline to read before speaking to anyone. Both reach the same place. Neither engages the firm.

Engagement is by acceptance. Every prospective engagement is reviewed, and engagements are formalized only by written agreement. Submitting the diagnostic is not an offer of, or agreement to, services.

No. Most of this practice is with clients outside the United States, and the work is done remotely. A CPA licence is issued by a state, but federal tax practice is federal: the Enrolled Agent credential is issued by the IRS and applies nationwide, wherever you are. The office is in Kissimmee, Florida, in the Greater Orlando area, and clients are welcome there by appointment.

This site and our written work are in English. The wider practice offers support in other languages; ask when you write and we will tell you what is available for your matter.

Fees depend on the structure and the state of the records, so we quote after we understand the matter rather than from a price list. What we can say is that this is advisory work priced accordingly, and that it is not the right service for someone who needs a single form filed as cheaply as possible.

Nothing on this site is a promise of a particular tax outcome. Figures shown are illustrative of the mechanics discussed, not projections for any specific taxpayer. Results depend entirely on facts, jurisdiction, and the instruments in force at the time.