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.

READ MORE →

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.

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…