Buying a condo in Miami is the easy part. The Italian fiscal calendar — IVIE, Quadro RW, FIRPTA, US estate tax — runs for the entire ownership period.
Full Italian fiscal lifecycle of US real estate ownership: purchase, holding, rental, sale, succession.
Fixed fee defined case-by-case after a preliminary consultation, based on the phase of the ownership lifecycle (pre-purchase structuring, ITIN, annual Quadro RW + IVIE, FIRPTA at sale, succession planning) and the complexity of the property structure. 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.
It depends on the use case. Personal vacation home with no rental: direct ownership is simpler but exposes you to US estate tax above $60,000 of value. Rental property: LLC offers liability protection and potentially shifts the asset's situs out of US for estate tax purposes. We map the choice during the Diagnostic.
Yes. Rental income from US real estate is US-source income. Without an election, rental income is subject to 30% gross-basis withholding by the property manager. Most owners elect Effectively Connected Income (ECI) treatment under IRC §871(d) — they file Form 1040-NR, deduct expenses and depreciation, and pay tax only on net rental profit at graduated rates.
FIRPTA requires the US buyer to withhold 15% of the gross sale price when a foreign seller disposes of US real estate. Example: a $500,000 sale triggers $75,000 withholding remitted to the IRS. The seller files Form 1040-NR to compute actual tax on the gain and recovers the excess as a refund — usually 12–18 months later. A pre-sale withholding certificate (Form 8288-B) can reduce this.
Italian residents must declare net rental income from US real estate on the Italian tax return as foreign-source income. US tax paid on the rental is creditable in Italy under art. 165 TUIR. The property is also reported on Quadro RW and is subject to IVIE at 0.76% annually.
If owned directly, US estate tax applies on value above $60,000 (rates up to 40%), the asset goes through Florida probate (6–18 months), and Italian inheritance tax applies under Italian law. If owned through a properly structured LLC, the situs may shift outside the US, eliminating US estate tax. Probate may also be avoided.
Yes, when you elect ECI treatment. Residential US real estate is depreciated straight-line over 27.5 years on Form 1040-NR. Depreciation lowers the annual taxable rental income but reduces basis at sale, increasing the eventual capital gain. We model the lifecycle.
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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.
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