Italy ↔ USA Cross-Border Legal and Tax Practice

The full Italy–USA framework: 1984 Income Tax Treaty (1999 protocol), FBAR / FinCEN 114, FATCA, Italian Quadro RW with IVAFE and IVIE, fiscal residency tie-breakers (Italian art. 2 TUIR + Treaty art. 4), Florida LLC structuring, PFIC, GILTI and exit tax.

The Italy–USA corridor: where problems actually arise

Almost every cross-border file we see fails at one of five points: tax residence, entity classification, reporting, treaty application, or timing between the two tax years.

• Tax residence: substantial presence in the U.S. versus AIRE registration and Italian residence rules — both countries can claim you in the same year.
• Entity classification: a U.S. LLC treated as transparent in the U.S. and potentially differently in Italy.
• Reporting: FBAR (FinCEN 114) above USD 10,000 aggregate, Form 5472 for foreign-owned single-member LLCs (USD 25,000 penalty), Italian Quadro RW with IVIE and IVAFE.
• Treaty application: relief is not automatic — it depends on the article invoked, the documentation and the order of filings.
• Timing: the Italian and U.S. tax calendars do not line up, and credits claimed in the wrong year are lost.

Moving money, business and people between the two countries

Every engagement starts with a 45-minute online consultation (USD 250) or a free written contact request. We reply in Italian or English, usually within one business day.

• Setting up in the U.S.: LLC or corporation, EIN, bank account, registered agent, state filings.
• Distributing profit back to Italy: withholding, treaty rates, Italian taxation of the distribution.
• Employment and social security: totalization between INPS and U.S. Social Security, avoiding double contributions.
• Property: purchase structure, rental income, FIRPTA on sale, estate tax exposure on U.S.-situs assets.
• Succession: U.S. estate tax on U.S.-situs assets for non-resident non-citizens, alongside Italian succession rules.

Where we work — office and areas served

Italy ↔ USA Cross-Border Legal and Tax Practice is handled from our Florida practice for Italian clients living in the United States and in Italy: office in St. Petersburg (Pinellas County, Tampa Bay), assistance across Florida — including Miami and South Florida — and remotely throughout Italy.

Physical office (by appointment): IIILEX International Consulting LLC, 7901 4th St N STE 300, St. Petersburg, FL 33702, US · +1 (786) 604-8763 · +39 335 344 9660 · us@3lex.us

Areas served

• St. Petersburg and Pinellas County, Florida (physical office)
• Tampa, Clearwater and the wider Tampa Bay area
• Miami, Miami-Dade, Fort Lauderdale/Broward and Palm Beach (South Florida)
• Orlando, Naples, Sarasota and the rest of Florida
• United States nationwide, remotely (federal tax and cross-border matters)
• Italy: Milan, Rome, Turin, Bologna, Naples and the whole country, remotely

Office hours: Monday to Friday, 09:00–18:00 (US Eastern Time). Italian clients are also served in the Italian morning window (CET). Working languages: Italian and English.

Consultations are held online (video call) or in person at the St. Petersburg office. Documents are exchanged securely by e-mail.

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Next step — book a 45-minute online consultation

Book a consultation (USD 250 · 45 minutes) · Send a contact request

About the firm

IIILEX International Consulting LLC is the Florida-based practice of Avv. Dott. Massimo Leonardi — Italian-qualified Attorney (Avvocato), Dottore Commercialista and Statutory Auditor (Revisore Legale), qualified in Italy, with 30+ years of Italian practice. We work exclusively on cross-border matters between Italy and the United States, in coordination with licensed U.S. professionals for matters of U.S. law.

IIILEX International Consulting LLC · 7901 4th St N STE 300, St. Petersburg, FL 33702 · us@3lex.us · +1 (786) 604-8763 · +39 335 344 9660

Versione italiana

Massimo Leonardi is admitted to practice law in Italy and is not admitted to practice law in Florida or elsewhere in the United States. He is qualified in Italy as Dottore Commercialista and Revisore Legale and is not a U.S. Certified Public Accountant. IIILEX International Consulting LLC provides cross-border consulting and Italian legal and tax advisory services. Matters requiring advice on U.S. or Florida law are handled in coordination with appropriately licensed U.S. professionals.