Practice Area · I.

United States cross-border tax.

ITA advises U.S. citizens, green-card holders, families, founders and investors whose tax position connects the United States with Italy or another international jurisdiction.

The Practice

Two countries, one coordinated position.

U.S. citizenship-based taxation continues after a move. The structure must coordinate both countries before residence, compensation, investments or company management change.

Decision FirstThe strongest planning window is before Italian residence begins, before equity compensation vests, before a U.S. entity is managed from Italy and before foreign investments are sold.

Four Service Areas

Italy and the United States tax different facts in different ways.

Each area is assessed on its own facts and then coordinated with the others, so that a position taken in one country does not create an unexpected exposure in the other.

i.

Relocation to Italy

Residence timing, Impatriati, Article 24-bis, the 7% pensioner regime, treaty residence and the combined Italian-U.S. projection.

ii.

U.S. Reporting

FBAR, FATCA Form 8938, foreign tax credits, FEIE, foreign pensions, PFICs and cross-border information returns.

iii.

Business Owners

LLCs, partnerships, S corporations, C corporations, compensation, permanent establishment, CFC and effective-management exposure.

iv.

Estate and Succession

U.S. citizenship and domicile, Italian succession, treaty coordination, ownership, beneficiary designations and lifetime transfers.

What We Deliver

Analysis that works in both countries.

  • Residence and treaty analysis.
  • Dual-country tax projections.
  • Income sourcing and foreign tax credit mapping.
  • Entity classification and governance review.
  • PFIC, FATCA, FBAR and foreign-asset exposure mapping.
  • Implementation sequence and adviser coordination.

U.S. and Italian conclusions are developed together. A saving in one country is not accepted as a strategy until the residual tax and reporting in the other country have been measured.

Strategic Timing

Build the position before the move.

The strongest planning window is before Italian residence begins, before equity compensation vests, before a U.S. entity is managed from Italy and before foreign investments are sold. ITA distinguishes preliminary strategy from formal return preparation and coordinates local filings where required.

Frequently Asked Questions

U.S.–Italy cross-border tax, clarified.

Does moving to Italy end U.S. taxation?
No. U.S. citizens and green-card holders generally remain subject to U.S. tax and reporting on worldwide income. Italian residence adds a second system that must be coordinated through domestic rules, the treaty and foreign tax credits.
When should cross-border planning begin?
Ideally before Italian tax residence starts, equity compensation vests, investments are sold or a U.S. business begins to be managed from Italy. Timing can change both the tax result and the available elections.
Are FBAR and FATCA the same obligation?
No. FBAR is a separate financial-account report filed with FinCEN, while FATCA reporting commonly includes Form 8938 with the federal income-tax return. Different thresholds, definitions and filing rules apply.
Can Italian tax always be credited against U.S. tax?
No. Creditability depends on the tax, the income category, source rules, timing and the applicable Form 1116 or corporate limitation. A nominal Italian saving can also create residual U.S. tax.
How are U.S. companies affected when the owner moves to Italy?
The analysis may include Italian effective management, permanent establishment, entity classification, compensation, CFC rules and U.S. information returns. The legal form alone does not determine the combined result.
Does a discovery call include technical advice?
No. The complimentary call is limited to fit and scope. Technical analysis is provided only through a paid consultation or a signed professional engagement.

Consultation Options

Discuss your U.S.–Italy position.

Start with a complimentary discovery call for fit and scope, or book a strategic consultation for a preliminary technical review and action sequence.

Initial Fit & Scope

Complimentary Discovery Call

15 minutes · Free of charge

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.

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.