Representative Engagements
Cross-Border Tax Case Studies.
An anonymised view of the questions, constraints and coordinated decisions behind complex international tax mandates.
The Purpose
Advice understood through real decisions.
Cross-border tax work is rarely defined by a single rule. Residence, entity classification, treaty access, reporting, succession and timing frequently interact across more than one jurisdiction.
These case studies show how representative mandates were framed and coordinated. Identifying facts have been removed or altered, and some matters combine recurring features from more than one engagement to preserve confidentiality.
Published Case Studies
Detailed cases for further reading.
Two anonymised cases examine the facts, cross-border tax questions and decision framework in greater depth.
Retirement Planning · U.S. → Italy
A U.S. couple retiring to Italy: the ten tax questions addressed first.
A structured review of residence, retirement income, investment accounts, property, reporting and succession before implementing the move.
- Core questionHow the couple’s U.S. income and assets interact with Italian residence and available regimes.
- Advisory focusSequencing the questions before choosing a regime or changing the investment structure.
Real Estate · U.S. → Italy
A 1031 exchange before moving to Italy: a quantified cross-border decision.
A U.S. real-estate investor needed to test federal deferral against Italian taxation, timing and the economics of the intended relocation.
- Core questionWhether a U.S. tax deferral remains efficient once Italian residence begins.
- Advisory focusComparing the tax cost, timing risk and implementation alternatives across both systems.
Selected Mandates
The case study archive.
Each profile is intentionally concise. It identifies the core issue, the advisory approach and the principal areas coordinated—not confidential client facts or a promise of comparable results.
Founder Mobility · U.S. → Italy
Pre-move planning for a founder with an active U.S. company.
The mandate required the client’s personal move to be assessed alongside company management, equity compensation and continuing U.S. filing obligations.
- Core questionHow to separate personal relocation from corporate residence and permanent-establishment risk.
- Advisory pathResidency timeline, governance protocol, compensation review and coordinated U.S.–Italy compliance map.
- ResolutionA phased move plan with documented decision points and jurisdiction-specific implementation.
Dual-Filer Compliance · U.S. & Italy
Restoring bilateral compliance after years of fragmented filings.
A dual-connected individual had Italian accounts, U.S. reporting duties and prior returns prepared without a single cross-border information set.
- Core questionWhich omissions required correction, disclosure or supporting documentation in each jurisdiction.
- Advisory pathAccount inventory, filing-gap analysis, treaty position review and sequenced remediation.
- ResolutionA coordinated compliance record designed to avoid inconsistent factual positions across filings.
Private Client · Relocation to Italy
Comparing Italian regimes for an internationally invested family.
The family’s income profile, investment holdings, succession objectives and expected duration in Italy made headline tax rates an incomplete basis for the decision.
- Core questionWhich residence and tax framework remained coherent across income, wealth reporting and family objectives.
- Advisory pathEligibility testing, source-by-source modelling, asset review and pre-arrival calendar.
- ResolutionA documented regime selection with conditions, exclusions and annual compliance requirements made explicit.
Estate & Succession · U.S.–Italy
Coordinating succession for assets and heirs on both sides of the Atlantic.
Ownership, domicile, forced-heirship considerations and different transfer-tax systems had to be analysed as one succession architecture.
- Core questionHow title, beneficiary designations and testamentary documents would interact at death.
- Advisory pathAsset-and-heir map, treaty review, document coordination and implementation with local counsel.
- ResolutionAn aligned succession plan that identified conflicts before documents and ownership arrangements were finalised.
Corporate Structure · Europe & U.S.
Reassessing a U.S. entity used by an Italy-based entrepreneur.
The entity’s place of formation did not answer where management occurred, how it was classified in Italy or whether its operational substance supported the structure.
- Core questionWhether the existing entity remained defensible once control and operations were viewed cross-border.
- Advisory pathClassification analysis, management-and-control review, CFC and permanent-establishment risk assessment.
- ResolutionA substance-led restructuring roadmap with tax, governance and compliance workstreams.
Real Estate · Italy → U.S.
Sale of Italian property after the owner became U.S. resident.
The transaction required coordinated analysis of Italian gain, U.S. reporting, currency effects, basis records and the availability and timing of foreign tax credits.
- Core questionHow one disposal would be computed, reported and documented under two tax systems.
- Advisory pathBasis reconstruction, source and timing analysis, closing-document review and credit coordination.
- ResolutionA transaction file and filing plan designed around consistent calculations and evidence.
Advisory Method
One mandate. Four disciplines.
The precise workstream changes with the facts, but the analytical sequence remains consistent.
Establish the facts.
Residence, citizenship, ownership, income, assets, family objectives, timing and prior compliance are mapped before solutions are considered.
Identify conflicts.
Domestic rules, treaty positions, entity classifications and reporting duties are tested across all relevant jurisdictions.
Model the choices.
Available paths are compared for legal sustainability, economic substance, total tax cost, administration and execution risk.
Coordinate execution.
Advice, filings, governance and specialist counsel are sequenced so that implementation follows one coherent factual position.
Professional notice.
All case studies are anonymised and condensed. Identifying facts may have been generalised, combined or altered to protect confidentiality. They are presented solely to illustrate the nature of cross-border analysis and do not disclose a complete client file.
Nothing on this page constitutes tax, legal, investment or financial advice. Tax outcomes depend on individual facts, applicable law, treaty interpretation and administrative practice at the relevant time. No result is guaranteed, and prior engagements do not predict the outcome of another matter.
A Confidential First Step
Your facts require their own analysis.
Discuss the jurisdictions, timing and decision points that define your cross-border position.