Italy–USA tax compliance

The largest part of our published work: how the two tax systems overlap, where relief actually exists, and which positions have to be documented before they are claimed.

Double taxation is rarely the result of a missing rule; it is the result of two systems applying their own rules to the same income in the same year. Residency, source and timing decide the outcome, and the convention allocates taxing rights only once those three are settled.

Italian tax and Italian law positions are handled directly by Avv. Dott. Massimo Leonardi, qualified in Italy as Avvocato, Dottore Commercialista and Revisore Legale. U.S. filings and U.S. law questions are coordinated with licensed U.S. professionals.

Publications in this topic

Selling into the U.S. Without a U.S. Entity: USTB, ECI and the Italy–U.S. Treaty — An Italian company can sell to U.S. customers without a U.S. subsidiary, but that does not mean no U.S. tax. How the U.S. trade or business and ECI tests interact with Articles 5 a
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 complete corrective fil
Moving from Italy to Florida? 10 Tax and Legal Steps to Take Before You Move — Moving from Italy to Florida is a tax event, not just a change of address: Article 2 TUIR residency tests, AIRE, Italian assets and S.r.l. shareholdings, U.S. worldwide taxation, P
I Live in Italy and Own a Florida LLC: Where Do I Pay Taxes? A 2026 Cross-Border Guide — Italian resident with a Florida LLC: how U.S. and Italian tax rules interact. Disregarded entity classification, effectively connected income, Quadro RW and the U.S.–Italy tax trea
U.S. Business Bank Account for Italian Residents: IRS Compliance and Italian Reporting Obligations — Italian residents with a U.S. business bank account face Quadro RW, IVAFE and Form 5472 obligations. Thresholds, penalties and deadlines explained for 2026.
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.
Italian Lawyer & Attorney in Florida: When You Need One — When Italians in Florida actually need an Italian-qualified lawyer or Dottore Commercialista, what cross-border work looks like in practice, and how to evaluate a firm.
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 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.
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.
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
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
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
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.
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
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.
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.
Italy–US Tax Treaty: How It Works and Which One Is in Force — Which Italy–US income tax treaty is actually in force, what it does and does not do, and the articles that decide real cases: residence tie-breaker, permanent establishment, divide

Related services

Italy-USA Double Taxation Treaty Advisory — Deep-dive advisory on the Italy-USA Tax Treaty signed 1999 (in force since 2010): every article that matters for cross-border individuals and businesses.
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.
PFIC: Italian Funds for US Residents — PFIC analysis, election strategy and Form 8621 filing for Italians with mutual funds, ETFs and SICAVs who become US tax residents.
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.

Publications by topic

U.S. LLCs and corporate structure — Everything we publish on U.S. company structure for Italian founders and investors — from the first filing to the ongoing obligations most people discover too late.
U.S. and Italian reporting: FBAR and Quadro RW — Reporting obligations run in both directions. These guides cover the U.S. side (FBAR) and the Italian side (Quadro RW) of the same accounts.
Italy–USA tax compliance — The largest part of our published work: how the two tax systems overlap, where relief actually exists, and which positions have to be documented before they are claimed.
Social security between Italy and the United States — Contribution years earned on one side of the Atlantic are not lost — but they only count if the coordination is claimed correctly and in time.
U.S. property and cross-border inheritance — Property and inheritance are where a structure set up years earlier either works or becomes expensive. These guides cover both sides of that moment.
Moving, visas and Italian litigation — Immigration and litigation both start with a deadline. These guides set out what has to exist before the filing, not after.

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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. 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 · 1200 Brickell Ave, Suite 310, Miami, FL 33131 · 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.