International Taxation

Individual and business tax advice, pre-immigration and expatriation tax planning, international tax reporting and compliance, and cross-border estates, trusts, wealth and succession advisory services

If you are a resident person or company with activities, investments or operations abroad or a nonresident person or company with income, investments or operations within the U.S. or Italy, you are confronted with a vast array of legal and international tax issues. The tax treatment of your income, investment or business activities is determined by the application of the internal laws of the country of which you are resident and the foreign host country co-ordinated and limited under any applicable double income tax treaty.


Areas of Practice

International Tax Planning, Reporting and Compliance for Individual Taxpayers

Foreign taxpayers (nonresident individuals) who move to Italy or the U.S. for a limited period of time or to live there permanently are exposed to the risk of being subject to tax in Italy or the U.S.

Taxation of Portfolio Income and Withholding Tax Issues

Portfolio income arises from investments in stock and bonds, licensing of intellectual property (patents, trademarks, copyrights, proprietary information), purchasing units of collective investment funds…

Global and International Tax Planning and Structuring of International Transactions

If you are planning a cross-border transaction, operation or investment you must deal with a multitude of tax issues and a broad array of tax rules, each with different and interdependent, short-term and long-term tax consequences.

Taxation of Business Income and Permanent Establishment Issues

Foreign taxpayers engaged in an active trade or business in the host country are usually subject to income tax in that county. The tax applies on net income (gross profit less deductible costs ad expenses)…

Taxation of Outbound Investments and Activities

U.S. or Italian taxpayers with investments or business operations in a foreign country are subject to tax in the foreign country, which taxes the income on the basis of source, and in their home (residence) country…

Tax Treaties and Competent Authority Procedures

Countries enter into bilateral income tax treaties to govern the allocation of respective taxing rights to avoid double taxation of their residents with respect to income arising in their respective territories.

Transfer Pricing

If you are a multinational enterprise with cross-border transactions with related entities you probably know that transfer pricing enforcement is a high-profile and big-money priority for tax authorities around the world.

International Tax Audits for Companies and Individuals

We assist corporate and individual clients in tax audits involving international tax matters and requiring specific international tax expertise and advice.

Tax assistance for Italian companies and partners in the US

Italian companies operating in the US market have to deal with two distinct levels of taxation: the federal, corporate income tax…