Washington, DC Accounting Firm | International Tax Page | Michael Rinaldi & Company LLP

Founded on the principle of building value by delivering solutions, the firm advises a diverse group of domestic and international clients on cross border tax and accounting matters. We use an academic approach to develop customized strategies to lower effective tax through novel treaty application as well as methodologies to make advantageous, new law and treaty provisions. Well versed in working with multi-disciplinary international teams, the firm’s expertise ranges from tax advice for family offices structuring operations abroad to taxation of high-net worth individuals.

Michael Rinaldi & Co. LLP specializes in cross-border financial structures and optimized financial instruments for investment in real estate, advising European investment banks and private equity real estate opportunity funds with regard to formation, acquisitions, dispositions and development of significant properties and portfolios, both in the United States and abroad.

Subject Matter Expertise

  • Tax Treaty Applications and Interpretation

  • Foreign Account Tax Compliance Act (FATCA)

  • Foreign Investment in Real Property Tax Act (FIRPTA)

  • Tax Planning & Compliance for Passive Foreign Investment Companies (PFIC)

  • Certification of Tax Residency

  • Formation of Interest Charge Domestic International Sales Corporation (IC-DISC)

  • Tax-effective Use of Offshore Trusts & U.S. Compliance – Form 3520

  • IRS Offshore Voluntary Disclosure Initiative

  • US Compliance and Withholding tax – Forms 926, 5471, 5472, 8865, W8BEN

  • Business Succession Planning for U.S. and Multinational Families

  • Inbound and Outbound Investments

  • Private Equity Fund Structuring

  • Real Estate Opportunity Funds

  • Cross Border Acquisitions


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