Practice Area · IV.
Estate & wealth planning.
Cross-border succession, US estate tax, Italian inheritance regimes and family governance — the architecture that protects wealth across generations and jurisdictions.
The Practice
Wealth, designed to endure.
Succession is rarely a single event. It is the result of decisions taken over decades — about residency, structure, governance and the legal regime that may eventually apply. We advise families and principals on the tax and planning considerations that shape cross-border wealth transfers, coordinating fiscal exposure, family objectives and legal continuity with the appropriate qualified professionals where required.
Six Workstreams
A practice built on continuity.
- i.
Italian Succession & Inheritance Tax
Italian inheritance and gift tax planning under Testo Unico delle Successioni, with EU Regulation 650/2012 succession-law election.
- Italian 4%–8% inheritance tax bands
- Spousal and lineal allowances (€1M)
- Patto di famiglia for business succession
- EU 650/2012 professio iuris election
- ii.
US Estate & Gift Tax
Federal estate and gift tax planning under §2001 and §2501, with lifetime exemption strategy and non-resident alien exposure.
- $15M federal basic exclusion amount for 2026
- Non-resident alien $60K threshold
- QDOT for non-citizen spouses
- US-Italy Estate Tax Treaty 1955
- iii.
Trust Structuring & Recognition
Anglo-Saxon and civil-law trust planning, including Italian recognition under L.364/1989 and analysis under the current Italian trust tax framework.
- Revocable and irrevocable trust design
- Italian opaque vs transparent trust regime
- Trust tax reform 2024 application
- Cross-border distributions and reporting
- iv.
Generation-Skipping & Multi-Tier Planning
GST planning under §2611 and Italian multi-generational structures for the orderly transfer of wealth across two or more generations.
- GST exemption allocation strategy
- Dynasty trust design (US)
- Italian usufrutto and nuda proprietà
- Multi-tier holding for legacy assets
- v.
Family Holding & Governance
Italian and Luxembourg family holding structures, family constitutions and governance protocols for principals and next-generation members.
- Holding finanziaria di famiglia design
- SOPARFI family-office vehicle
- Family constitution and protocols
- Voting trusts and shareholder agreements
- vi.
Philanthropy & Private Foundations
Italian Fondazioni di Famiglia, US private foundations and donor-advised funds for structured philanthropic giving and legacy planning.
- Italian Fondazioni di Famiglia setup
- US §501(c)(3) private foundations
- Donor-Advised Fund strategy
- Cross-border charitable deductions
Succession Lens
Three regimes, one legacy.
Italy
SUCCESSIONI
INHERITANCE TAX
4% spouse / lineal · 6% siblings · 8% others
EXEMPTION
€1,000,000 per heir (spouse / lineal)
FORCED HEIRSHIP
Legittima — spouse and descendants protected
Worldwide assets if resident · EU 650/2012 election available
United States
FEDERAL ESTATE
ESTATE TAX RATE
Up to 40% above exemption threshold
EXEMPTION
$15M basic exclusion (2026) · $60K NRA threshold
SPOUSAL TRANSFER
Unlimited marital deduction · QDOT for non-citizens
Worldwide for US persons · US-situs only for NRA
Treaty
US-ITALY 1955
SCOPE
Estate tax only — no gift or GST coverage
DOMICILE TIE-BREAKER
Permanent home · habitual abode · nationality
CREDIT MECHANISM
Foreign Estate Tax Credit under Article IV
Limited treaty · careful planning required for dual exposure
Consultation Options
A legacy is not assembled
in a single generation.
Choose an introductory call to discuss fit and scope, or reserve a strategic consultation for preliminary review of your cross-border estate and succession concerns.
Initial Fit & Scope
Complimentary Discovery Call
An introductory conversation to understand your situation, determine whether the firm is the right fit and define the scope of a possible engagement. No technical tax, legal, estate planning, investment or financial advice is provided during this call.
The pre-call questionnaire must be completed before the appointment is confirmed.
Strategic Preliminary Review
Estate Planning Consultation
Includes preliminary review of submitted information, strategic discussion with Laura Giacomini, identification of key cross-border tax, residency, reporting and succession issues, and an initial action plan. The fee is credited toward future professional services if a formal engagement is established.
Payment is required at booking via Stripe. The pre-consultation questionnaire must be completed before confirmation.
Rescheduling requests require at least 24 hours’ notice. No-shows or late cancellations for paid consultations may not be refundable. Formal advice is provided only after a written engagement has been accepted and signed.