USA

Transfer Pricing in the U.S. - Chartered Institute of Taxation, Milan (Italy), October 15, 2010

A Framework for Italian Enterprises Entering the U.S. Market

Italy Clarifies Withholding Tax Treatment of EU Dividends - in Tax Notes Int'l, June 1, 2009, p. 730.

Italy Passes New Law Targeting Abusive Transactions - in Tax Notes Int'l, February 9, 2009, p. 506.

Taxpayers Bear Burden of Proof in Avoidance Cases, Supreme Court Says - in Tax Notes Int'l, May 11, 2009, p. 482.

New Tax Form Addresses Tax Groups’ Interest Deduction Limitations - in Tax Notes Int'l, February 9, 2009, p. 507.

Outbound Merger Not Tax-Free, Tax Authority Says - in Tax Notes Int'l, February 9, 2009, p. 506.

Large-Case Audit Program Introduced - in Tax Notes Int'l, January 19, 2009, p. 220.

Supreme Court Confirms General Antiavoidance Principle - in Tax Notes Int'l, January 19, 2009, p. 219.

ECJ Addresses Cross-Border Share Transfers - in Tax Notes Int'l, January 5, 2009, p. 36.

Finnish Tax on Dividends Violates EC Treaty - in Tax Notes Int'l, January 5, 2009, p. 41.

Tax Authority Rules on Change of Residency During Tax Year - in Tax Notes Int'l, December 15, 2008, p. 857.

Tax Authority Rules on Cross-Border Tax-Free Mergers - in Tax Notes Int'l, December 15, 2008, p. 856.

An Italian Perspective on Recent ECJ Direct Tax Decisions - in Tax Notes Int'l, June 2, 2008, p. 775.

Officials Grapple With Corporate Tax Residency Issues - in Tax Notes Int'l, January 28, 2008, p. 334.

Italy introduces Broad Corporate Tax Reform - in Tax Notes Int'l, January 28, 2008, p. 307.

Overview of Italy's Corporate Tax Reforms for 2008 - Presented at IFA USA, Westchester/Connecticut Region, January 10, 2008.

Italy: 2007 Year in Review in Tax Notes Int'l, December 31, 2007, p. 1374

Italian Taxation of Trusts - Presented at California State Bar Tax Section Meeting, San Diego, CA, November 2-4, 2007

Italy Clarifies Domestic Trust Provisions - in Tax Notes Int'l, October 15, 2007, p. 225

Tax Administration Clarifies Treatment of Foreign Partnerships in Tax Notes Int'l, August 13, 2007, p. 651

Telecom Italia Deal Hit With Massive Tax Bill - in Tax Notes Int'l, August 13, 2007, p. 649

Court Rules on Characterization of Subsidiary - in Tax Notes Int'l, August 6, 2007, p. 510

Tax Authorities Issue Ruling on IT Server and Permanent Establishment - in Tax Notes Int'l, June 4, 2007, p. 1006

Government Clarifies High-Tax Exception to CFC Rules - in Tax Notes Int'l, April 23, 2007, p. 355

Italy’s 2007 Budget Law and Related Tax Act - in Tax Notes Int'l, April 23, 2007, p. 391

Beneficial Ownership and Tax Treaties  - presented at IFA USA, Westchester/Connecticut Region, March 8, 2007,

The Concept of Beneficial Ownership and Italian Tax Law - ABA Tax Section Meeting, Hollywood, Florida, January 19, 2007

Update on Latest ECJ Tax Rulings, presented at IFA USA Westchester/Connecticut Region, January 11, 2007

Italy: 2006 Year in Review - in Tax Notes Int'l, December 25, 2006, p. 1064

Italian Supreme Court Wants Clarity on Halifax Test - in Tax Notes Int'l, December 4, 2006, p. 735

Nonresident Service Provider Escapes Income Tax, Not VAT - in Tax Notes Int'l, December 4, 2006, p. 753

Tax Authorities Bear Burden of Proof, Italian Court Says - in Tax Notes Int'l, November 27, 2006, p. 667

Supreme Court Recharacterizes Company as PE - in Tax Notes Int'l, November 20, 2006, p. 585

Supreme Court Recharacterizes Company as PE - in Tax Notes Int'l, November 13, 2006, p. 507

Tax Commission Recharacterizes Subsidiary as PE of Foreign Parent - in Tax Notes Int'l, November 6, 2006, p. 427

Using Dual Resident Companies Under Italy's Tax Consolidation Rules - in Tax Notes Int'l, October 16, 2006, p. 205

Italy Introduces Corporate Tax Residency, Anti-Inversion Rules - in Tax Notes Int'l, August 28, 2006, p. 699

Italy Clarifies Scope of Antiabuse Rule - in Tax Notes Int'l, July 3, 2006, p. 7

Italy's International Tax Ruling Procedure - in Tax Notes Int'l, May 29, 2006, p. 797.

Italy Clarifies Rules For Determining Branch Income - in Tax Notes Int'l, May 22, 2006, p. 675

Italy Addresses Treaties and Transparent Entities - in Tax Notes Int'l, March 20, 2006, p. 947

Italy Amends Rules on Participations Exemption, Portfolio Dividends - in Tax Notes Int'l, February 6, 2006, p. 411

Italy's Participation Exemption Rules - in Tax Notes Int'l, December 5, 2005, p. 907

Tax Treaties, Hybrid Entities and Tax Planning: General Presentation, International Fiscal Association - Presented at New York Region International Tax Seminar, New York, November 17, 2005;

Tax Treaties, Hybrid Entities and Tax Planning: the Italy-US Perspective, International Fiscal Association - Presented at New York Region International Tax Seminar, New York, November 17, 2005;

Italy’s Thin Capitalization Rules - in Tax Notes Int'l, October 3, 2005, p. 89;

Italy’s New Check-the-Box Rules - in Tax Notes Int'l, July 25, 2005, p. 1152;

Italy Issues Tonnage Tax Regs - in Tax Notes Int'l, July 18, 2005, p. 217;

Italy Implements EU Savings Tax Directive - in Tax Notes Int'l, June 27, 2005, p. 329