U.S. Clients In Italy

We provide the full range of strategic tax and legal assistance for U.S. individual and business clients on U.S.-Italy transactions
and Italian legal and tax matters
We regularly assist U.S. individual clients, companies, businesses and investment funds on Italian legal and tax matters. For U.S. citizens living in Italy and owning assets and income in the United States, we provide Italian strategic tax planning and advice for the proper management of their Italian income tax reporting and filing obligations, in coordination with their tax filing and reporting duties in the United States. We assist U.S. clients in international tax audits in front of Italian tax agencies and international tax litigation in fronto of Italian tax courts.

We assist U.S. citizens living in Italy on their Italian tax filing and reporting obligations in coordination with their tax filing and reporting duties in the United States, and in Italian international tax audits and controversies.
For U.S. citizens and residents who own Italian assets and spend time in Italy, alone or with their families, for business or pleasure, we provide custom made and specifcally tailored advice on their Italian tax status for Italian tax filing purposes, handling tax residency issues arising under Italian law and U.S.-Italy Tax Treaty.

We assist U.S. citizens and residents with assets or investments in Italy or traveling to and spending time in Italy, on Italian tax residency issues arising under Italian law and the U.S.-Italy income tax treaty.
U.S. citizens and residents with estate planning, wills and trusts including Italian assets, or Italian resident beneficiaries, are exposed to Italian inheritance and trust rules, including Italian rules on taxation of foreign trusts. The way in which foreign trusts are classified and treated for Italian tax purposes under Italian law is not consistent with the way on which the same trusts are classified and treated in the United States. Also, reporting and disclosure obligations may arise upon foreign trustees, settlors or beneficiaries in respect of trusts with Italian assets or other connections with Italy.

We provide specialized Italian estate and trust legal and tax assistance to trustees, beneficiaries and settlors of U.S. trusts with connections to Italy.
For U.S. companies, business and investment funds planning investments in Italy or doing business in or with Italy in various shapes and forms, we provide full range of legal and tax services for the purpose of planning, executing and managing their Italian investment and business transactions.

We assist U.S. companies, business and investment funds on Italy inbound investments and business transactions

Areas of Practice

Italian Tax Residency Planning, Assistance and Advice for U.S. Citizens and Residents
U.S. citizens and residents who own houses in Italy, travelling to and spending time there regularly, alone or with their family, for business or pleasure, need to be aware of Italian tax rules on tax residency for individuals taxpayers. Italy assigns tax residency to individuals based on one of three alternative tests: registration on the Italian register of resident individuals, regular place of abode (true home) and domicile (main center of interests). The sole fact of being registered on the Italian list of resident individuals for more than 183 days in any given year triggers Italian tax residency. Place of abode and domicile depend heavily on the facts and circumstances of each particular case, such as the time spent in Italy and the nature, extent and number of ties or connections with the country at the personal, family, economic and business level.

Spending time in Italy, owning houses or investments there, and establishing other connections with Italy on personal, family, economic or business level may expose to Italian tax residency. Italian tax residency is determined pursuant to facts and circumstances tests revolving around the taxpayer's permanent home coupled with a subjective intention to remain there on a permanent basis, and his or her personal, family, economic and business contacts with Italy.
Tax residency requires careful planning and specific advice. Very often, tax audits are initiated on the tax status of U.S. citizens and residents in Italy as a result of or in connection with the purchase or ownership of Italian houses or other investment assets, opening of or holding Italian bank accounts, or the transfer of money from the U.S. into Italy (that is automatically registered in the Italian tax agency's data base).

Italian international tax audits on U.S. citizens and residents are often initiated in connection with the purchase or ownership of Italian houses, traveling to Italy and showing on the Italian list of resident individuals.      
Individual international tax audits in Italy require careful advice, to make sure that the case is closed upfront and to avoid the need to go to the tax court to challenge a tax assessment. Very often, U.S. tax legal, banking and tax documents must be used and properly explained to Italian tax authorities, and risks of misunderstanding and unintented outcome in the tax investigation are extremely high and dangerous. A clear understanding of U.S. information to be used in the Italian audits is crucial for that purpose.

Italian tax audits on U.S.-Italy cross border matters for individual taxpayers require specific expertise, proper use and presentation of U.S. legal, financial and tax information, and thourgh discussion of client's position with the Italian tax authority.          
Litigation of an international tax case before the Italian tax courts is extremely challenging, due to strict procedural rules, limitation on appeal rights, and the tax court's attitude generally inclined to rule in favor of tax agencies.

We assist U.S. clients with tax advice on Italian tax residency, strategic assistance in Italian international tax audits, and aggressive representation in tax court cases.
For U.S. clients whose Italian tax residency is established, we provide assistance on Italian income tax returns and international tax reporting and disclosure of U.S. and other on Italian assets on Italian tax return's section RW.

We assist U.S. clients on Italian international tax reporting on their U.S. and non Italian assets on Italian income tax return's Section RW 

In this area, we provide the following services:

  • Italian tax residency preliminary study, analysis and advice,
  • Italian pre-immigration tax planning,
  • Representation and assistance in international tax audits before Italian tax agencies,
  • Representation and assistance in international tax cases and controversies before Italian tax courts.