Italy receives automatic CRS/FATCA data on your US holdings. The Quadro RW must match — and reach a value precision that most generalist commercialisti underestimate for US assets.
Complete Italian foreign-asset reporting for residents with US LLCs, accounts, securities and real estate. Quadro RW + IVAFE + IVIE.
Fixed fee defined case-by-case after a preliminary consultation, based on the number of US assets to report, the years involved and whether ravvedimento operoso is required. The preliminary consultation is a 45-minute paid online session ($250); the engagement letter with the agreed fee is signed before any chargeable work begins.
Italian tax residents must report foreign financial assets if the aggregate value exceeded €5,000 at any point during the year. Foreign real estate must be reported regardless of value. The €5,000 threshold applies only to the reporting obligation; IVAFE and IVIE may apply at lower thresholds.
3% to 15% of the undeclared value, per year. The range extends to 6% to 30% if the asset is held in a tax-haven jurisdiction. The look-back period for assessment extends from 5 to 10 years for tax-haven assets. The US is not a tax haven, but specific structures may trigger the longer look-back.
IVAFE is a 0.2% annual tax on the value of financial assets held abroad. For US bank accounts, it is calculated on the year-end balance (or average balance for accounts that fluctuate significantly). For brokerage accounts holding securities, it is 0.2% of the year-end portfolio value.
IVIE is 0.76% annual tax on the value of foreign real estate. For US property, the value is generally the purchase price or, if available, the cadastral-equivalent value. Property taxes paid in the US are credited against IVIE under the Italy-USA treaty.
This is more common than people realize. We assess the omission, determine if ravvedimento operoso is available (it usually is), and quantify the catch-up cost. Sanctions are heavily reduced for voluntary correction before any audit notice.
Yes. The participation in the LLC is itself the asset. The value to declare is generally the proportional value of LLC net assets. If the LLC holds real estate, both the participation and an attribution of the real estate may need disclosure depending on the structure.
Yes. Quadro RW is for monitoring; IVAFE/IVIE are wealth taxes; income tax (IRPEF) is separate. An Italian resident with US LLC profits typically owes all three: Quadro RW reporting, IVAFE on financial value, IRPEF on attributed income.
Book a consultation (USD 250 · 45 minutes) · Send a contact request
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.
IIILEX International Consulting LLC · 7901 4th St N STE 300, St. Petersburg, FL 33702 · us@3lex.us · +1 (786) 604-8764 · +39 335 344 9660