Global Solutions — Italy ↔ USA Articles & Guides

Long-form articles and reference guides on the most consequential Italy–USA legal, tax and compliance topics — authored by an Italian Attorney, CPA and Statutory Auditor practicing on both sides.

In-depth guides

FBAR 2026: The Complete Guide for Italians with US Assets — Who must file the FBAR (FinCEN 114), the deadlines, the penalties for omission, and how the FBAR interacts with the Italian Quadro RW for Italian residents with US accounts in 2026
How to Open a Florida LLC as an Italian: Complete Guide 2026 — Step-by-step guide to forming a Florida LLC as an Italian resident — and the Italian fiscal obligations that follow that no online formation service mentions.
Quadro RW for Italians with US Assets: Complete 2026 Guide — Filing Quadro RW for US LLCs, accounts, real estate, and brokerage holdings — including IVAFE, IVIE, sanctions and the relationship with FBAR.
How Many Days Can You Stay in the US Without Becoming a Tax Resident? — The Substantial Presence Test, Closer Connection Exception, and treaty tie-breaker — the three lines an Italian must understand before increasing US presence.
Are Your Italian Funds PFIC? What Nobody Tells You Before Moving to the US — Italian UCITS funds are nearly all PFICs under US rules. Default treatment can tax a 10-year gain at retroactive top rates with interest charges that exceed the gain itself.
The 1984 Italy-USA Tax Treaty: Guide to Key Provisions — Article-by-article overview of the most-applied provisions: permanent establishment, dividends, royalties, capital gains, pensions, employment income.
IVAFE 2026: Complete Guide for Italians with US Assets — How IVAFE works in 2026 for Italian residents holding US bank, brokerage and crypto accounts: rates, tax base, calculation, exemptions and coordination with Quadro RW and FBAR.
Transferring Money from the US to Italy: 2026 Tax Treatment — When a wire transfer from a US account to an Italian account is taxable, when it isn't, what the receiving Italian bank reports, and how to document the source of funds to avoid pr
Crypto and Quadro RW 2026: Italian Residents with US Exchange Accounts — How Italian residents must declare crypto held with US exchanges (Coinbase, Kraken, Gemini): Quadro RW reporting, IVAFE 0.20%, capital-gains regime under L. 197/2022 and the 2025-2
E-2 Visa USA: Tax Aspects for Italian Investors — The E-2 Treaty Investor visa from the Italian side: when SPT triggers US tax residence, treaty tie-breaker, exit-tax exposure, Quadro RW maintenance, and the right structuring befo
Moving to Miami: How Italian Tax Residence Really Ends — Practical guide for Italians relocating to Miami: AIRE registration is not enough, the role of art. 2 TUIR, the Italy-USA Treaty tie-breaker, and the most common audit triggers in
FBAR Penalties for Italians: Willful vs Non-Willful (2026) — How FBAR penalties actually work in 2026: the willful vs non-willful distinction, recent Supreme Court guidance, the Streamlined Filing Compliance Procedures, and what Italians wit
Italians Moving to Florida: Legal & Tax Checklist (2026) — An end-to-end checklist for Italians relocating to Florida in 2026: visa selection, immigration milestones, tax-residency planning, business setup, banking, real estate and ongoing
Italian-American Dual Citizenship: Tax Implications (2026) — What dual Italian-American citizenship really means for tax: the US citizenship-based taxation principle, the FEIE and FTC, FBAR/8938 obligations, the renunciation question, and ho
Italy–USA Social Security: Totalization, Pro-Rata Pension and Tax Advantages — Complete guide for those who worked in the USA: the Italy–US Social Security Agreement, international totalization, pro-rata pension, double taxation and the impatriate regime.
Quadro RW and Foreign Bank Accounts: Thresholds, IVAFE and Penalties — When the Quadro RW filing obligation is triggered for foreign bank accounts: the EUR 15,000 threshold, IVAFE, Revolut and N26, CRS automatic exchange, and penalties from Agenzia de
Opening a U.S. Bank Account from Italy: Tax & Compliance Guide — Everything Italian residents need to know about opening a U.S. bank account: Quadro RW, FATCA, IVAFE, Italy–US Tax Treaty, and how to avoid costly mistakes.
IVIE 2026: Italian Wealth Tax on US Real Estate Explained — How IVIE works in 2026 for Italian tax residents owning US real estate: rate, tax base, exemptions, foreign tax credit and Quadro RW coordination.
IVAFE on US Brokerage & CIA Accounts: Codes, Calculation, Quadro RW — How IVAFE applies to US brokerage, custodial (CIA) and investment accounts held by Italian residents: rate, tax base, account codes and Quadro RW reporting.
Quadro RW Exemption: When Italian Residents Don't Have to File — When the Quadro RW exemption applies to Italian residents with foreign assets: thresholds, qualifying cases, and why most exemptions are narrower than they look.
Italian Wealth Tax on US Assets: IVIE, IVAFE & Future Scenarios — What the current Italian wealth tax actually is, how IVIE and IVAFE hit US assets, and which future-scenario patrimoniale proposals would change the cross-border picture.
Taxes in Italy for Americans: Practical Guide for US Citizens — How Italian taxes work for US citizens moving to Italy or investing there: residency, IRPEF brackets, capital gains, US filing, FTC and treaty positioning.
Italian Lawyer & Attorney in Florida: When You Need One — When Italians in Florida actually need an Italian-qualified lawyer or CPA, what cross-border work looks like in practice, and how to evaluate a firm.
US LLC and Disregarded Entity: The Tax Guide for Italian Entrepreneurs and Expats — Own a US LLC as an Italian resident? Your tax obligations in both countries — Form 5472, Quadro RW, Italy–USA Treaty, CFC rules, esterovestizione risk.
Florida Business for Italians: Less Paperwork, Same Rules — Italian entrepreneurs often discover Florida requires far less administrative burden than Italy. Here is what makes the difference — and what still matters for cross-border complia
Italy-U.S. Totalization Agreement: Pension Guide — Worked in both Italy and the U.S.? The Totalization Agreement lets you combine contribution periods from both countries to qualify for retirement benefits.
Emergency Injunctions in Italian Law: Article 700 Complete Guide — Italian civil litigation can take years, but Article 700 c.p.c. allows courts to grant interim relief within days when fumus boni iuris and periculum in mora are demonstrated. A co
E-2 Visa for Italian Entrepreneurs: Complete Guide 2026 — The E-2 Treaty Investor Visa is one of the most practical routes for Italian entrepreneurs entering the United States — but visa approval must be planned alongside Italian and US t
USA Business & Tax Guide for Italians (2026): LLC, Visas, Real Estate & Tax Treaty — The operational pillar guide for Italian entrepreneurs, investors and private clients entering the US market: LLC vs C-Corp, E-2/L-1/EB-5 visas, FIRPTA on real estate, 2026 taxatio
E-2 Visa USA: The Ultimate Guide for Italian Entrepreneurs — The United States offers unparalleled growth opportunities for Italian businesses. Discover why the E-2 Treaty Investor Visa is the top choice for Italian entrepreneurs relocating
Double INPS Contribution for Company Partners and Directors: When It Is Unlawful — Gestione Separata plus Gestione Commercianti at the same time: when INPS enrollment is unlawful, how to challenge the notice, and how to recover contributions already paid.
Florida LLC for Non-U.S. Residents: Formation, EIN, Banking and Form 5472 Compliance — Form a Florida LLC from abroad: EIN, banking, Form 5472 and the Italian tax side. What nonresident owners must file, and the $25,000 penalty to avoid.

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IIILEX International Consulting LLC is the Florida-based practice of Avv. Dott. Massimo Leonardi — Italian Attorney (Avvocato), Certified Public Accountant (Dottore Commercialista) and Statutory Auditor (Revisore Legale) with 30+ years of Italian practice. We work exclusively on cross-border matters between Italy and the United States.

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