International Tax & Cross-Border Planning (Italy–U.S.)
Cross-border tax planning between Italy and the United States means deciding residency, structure and timing before money or people move. IIILEX handles the Italian side directly and coordinates the U.S. side with licensed U.S. professionals, so the plan works in both countries.
Coordination of Italian and U.S. tax matters, pre-migration planning, cross-border structures and ongoing compliance.
What problem we solve
Typical situations
- Relocating from Italy to the U.S. (or the reverse) without a pre-migration review
- Uncertain tax residency under domestic rules and the Italy–U.S. treaty
- A U.S. company owned from Italy with no view of CFC, Quadro RW or treaty effects
- Income, pensions or investments taxed in both countries
What you receive
What IIILEX coordinates
- Italian tax analysis: residency, AIRE, Quadro RW, IVIE/IVAFE, CFC, foreign tax credit
- Treaty positioning (Convention signed 1999, in force since 16 December 2009)
- Pre-migration timeline: what to sell, restructure or document before moving
- Coordination with a U.S. CPA on the federal and state side of the same plan
- Written memo in English or Italian
Who this is for
Who it's for
- Italian entrepreneurs expanding or moving to the U.S.
- Americans and Italian-Americans moving to Italy
- Families with assets in both countries
Investment
Engagement
Start with a free request or the 45-minute online consultation (USD 250) with Avv. Dott. Massimo Leonardi. Any fee for coordination is agreed in writing case-by-case. U.S. professionals quote and engage directly with the client for their own regulated services.
Frequently asked questions
What is pre-migration tax planning between Italy and the U.S.?
It is the review done before a move to decide when residency changes, which assets to restructure and how each country will tax income and gains. Doing it after the move often removes options.
Does IIILEX prepare U.S. tax returns?
No. U.S. federal and state returns are handled by licensed U.S. CPA professionals. IIILEX covers the Italian side and coordinates the overall plan.
Can I be tax resident in both Italy and the U.S.?
Yes, under domestic rules. The treaty's tie-breaker rules then decide which country has primary taxing rights; U.S. citizens remain taxable in the U.S. regardless.
What is the first step?
A free request or the 45-minute consultation (USD 250) to frame the situation and decide whether U.S. professionals need to be involved.
Related services
- Italy-USA Tax Treaty Advisory — Advisory and certification on the Italy-USA Tax Treaty (signed 1999, in force since 2010): treaty positioning, withholding optimization, permanent establishment risk.
- US Tax Obligations for Italians Resident in the USA — Comprehensive cross-border compliance: Form 1040, FBAR, Form 8938, 5471, 8865, 8621, 3520, 8854 — coordinated with Italian filings.
- U.S. Tax & Accounting Coordination for Italy–U.S. Clients — Through independent U.S. CPA professionals: federal and state tax, accounting and compliance, aligned with the Italian side.
Guides related to this service
- Choosing the Right U.S. State for a Foreign-Founder LLC: Delaware, Florida, Wyoming and the Trade-offs — Delaware, Florida or Wyoming for an Italian-owned US LLC? A practical comparison of state fees, disclosure, taxation, banking friction and the interface with th
- How Much Does a Florida LLC Really Cost? A Guide for Italian Entrepreneurs — The $125 State formation fee is only the beginning. Registered Agent, EIN, banking, bookkeeping, the $138.75 Annual Report with its $400 late fee, Form 5472 com
- Doing Business in the United States: Structure Comes Before Speed — Forming a U.S. company takes days; structuring a U.S. business correctly takes planning. Entity selection, governance and deadlock rules, dual-jurisdiction taxa
- Do I Need a U.S. LLC to Sell in America? A Decision Guide for Italian Companies — Selling to U.S. customers does not automatically require an American company. The ETBUS and effectively connected income analysis, treaty permanent establishmen
- I Opened a Florida LLC From Italy: Now What? A Cross-Border Coordination Guide — Forming the LLC is the easy part. Italian tax residence, place of effective management under article 73 TUIR, Italian classification of the LLC, CFC rules, Quad
- Form 5472 Missed Filing and the $25,000 Penalty: Corrective Action for Italian LLC Owners — Missed a Form 5472 filing for your U.S. LLC? How the $25,000 penalty works, why the 90-day continuation clock is the most important date in the file, what a com
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.