Foreign companies entering the U.S. market or foreign nationals moving to the United States on temporary assignments or a more long term basis have to deal with international tax issues arising from U.S. internal tax laws and the Tax Treaty between the United States and their country of origin, understand their tax obligations in the U.S., and make sure they plan their activities properly and comply with their tax duties as arising under U.S. law.
That is the situation of Italian or U.S. domestic companies with investments or operations abroad and foreign companies with investments or operations in the U.S. or Italy, and resident individuals working abroad on a temporary assignment or a more permanent basis or non resident individuals relocating in Italy or the U.S.
Domestic companies doing business abroad must plan their operations in a way to minimize negative tax impacts under foreign jurisdiciton and in their home country.
Within the
EU the legal and tax treatment of a transaction is also affected by EC law, interpreted and enforced by the European Court of Justice, which override the internal laws of EC Member States.
U.S. citizen and resident alien individuals with assets or income outside of the United States are subject to extensive international tax reporting and disclosure obligations, which are subject to stiff penalties if neglected. Similarly, U.S. citizens living in Italy are subject to international reporting obligations under Italian tax law. Automatic exchange of information with foreign banks reporting accuonts held by U.S. citizens to the Internal Revenue Service, and between U.S. and Italy under the new treaty implementing FATCA legislation, create enormouns pressure toward full and timely compliance with international tax reporting rules.
U.S. citizens and resident alien individuals with assets or investments outside of the United States, and U.S. citizens in Italy, are subject to extensive and far reaching international tax reporting obligations, now effectively enforced through a system of automatic exchange of information concerning foreign financial accounts and associated income
International tax audits, both for global companies and individuals, are on the rise, and so is the risk of adverse tax assessments in the absence of expert advice and support on complicated cross border matters often going beyond the day to day work and understanding of tax agents. Tax administrations around the world have more effective tools to enforce their international tax rules and have increased international tax enforcement dramatically.
International tax enforcement and audits are on the rise, with additional risk of adverse tax assessments in the absence of a correct understanding of complex international tax issues.
Without adequate advice and tax planning you may easily end up incurring broader and unexpected tax liabilities or suffering double taxation. When a transaction involves three or more jurisdictions the issues multiply exponentially.
In this challenging area of international law we provide the full range of international tax and legal services for our corporate and individual clients engaged in international activities or facing international tax issues, as needed to properly plan cross border activities. In particular we cover the areas described below.
