An Italian who becomes US tax resident faces a stack of US filings — and each interlocks with Italian reporting in ways most US-only CPAs miss.
Comprehensive cross-border compliance: Form 1040, FBAR, Form 8938, 5471, 8865, 8621, 3520, 8854 — coordinated with Italian filings.
Fixed fee defined case-by-case after a preliminary consultation, based on the number of foreign entities and PFICs, the perimeter of the annual compliance package and the need for single-issue advisory or Streamlined catch-up filings. 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.
Many can — but the failure mode is the Italian side. A US CPA optimizes the Form 1040 in isolation and rarely coordinates with Quadro RW, IVAFE timing, Italian foreign-tax-credit limits, or the Italian classification of LLCs and US trusts. We sit in between.
Form 5471 for any Italian SRL/SpA the client owns ≥10% of. Most newly-arrived Italian residents don't realize the form is required, even with zero income. Penalty: $10K per form per year, automatically assessed.
Once you cross the Substantial Presence Test threshold, yes. Closer Connection (Form 8840) or treaty tie-breaker (Form 8833) may relieve full filings, but the analysis must be done annually. Don't assume; document.
You file Form 3520 if you receive a foreign gift or inheritance from a non-US person aggregating >$100K in a year (or >$18,567 from a foreign corporation/trust in 2024). Penalty for non-filing: 35% of the gift value. Common trigger: an Italian parent's gift to a US-resident child.
He or she remains essential for the Italian side. We complement on the US side and coordinate the two so filings reconcile. Pure 'Italian-only' coverage misses the FBAR, 8938, 5471, 8621 universe.
Likely yes, but typically fixable. Streamlined Foreign or Domestic Offshore Procedures cover non-willful failures: 3 years of 1040 amendments, 6 years of FBAR, no penalty other than tax + interest. Pre-emptive disclosure beats reactive. We assess and execute.
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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