
Marco Q Rossi
Marco Q. Rossi is the founder and principal of Marco Q. Rossi & Associati, PLLC, an innovative boutique international law firm dedicated to providing strategic legal and tax advice for cross-border business transactions and personal international legal and tax matters.
Background and Education
Marco was born and educated in Italy, earning his law degree from the University of Genoa School of Law in 1990. He began his career in international maritime law, serving as local counsel for major UK-based law firms and U.S.-based clients. In 2002, he obtained an International Tax LL.M. degree from New York University School of Law. In 2005, Marco founded Marco Q. Rossi & Associati as a U.S.-Italy cross-border practice with offices in both Italy and New York. In 2016, he expanded the practice by opening an office in Los Angeles, thereby operating seamlessly from both the east and west coasts of the United States while integrating with the firm’s E.U.-based offices in Italy.
Licenses and Practice Areas
Marco is licensed to practice law in Italy, New York, and California. He assists international clients and global families with strategic income tax, estate, and trust planning and compliance. His expertise extends to advising foreign-based multinational enterprises on U.S. inbound investments, acquisitions, and business transactions, as well as supporting U.S.-based companies with outbound business operations. Additionally, Marco advises international executive and managerial personnel employed across borders. In Italy, he maintains a sophisticated international tax practice, offering counsel to U.S. businesses and private clients on Italian international legal and tax matters.
Representative matters
- Advised a client on structuring an EU holding company as the entry point for investments into Italy, including the taxation of cross-border payments under applicable EU directives, statutory requirements, beneficial owner test, and anti-abuse rules to achieve withholding tax exemption
- Advised a client on Italian tax planning for the purchase and management of real estate investments, including cross-border tax issues related to international financing, profit repatriation, asset sales, and liquidation
- Advised a client on pre-immigration strategies ahead of relocating to Italy and establishing Italian tax residency, including analysis of income sources and character and pre-arrival restructuring to optimize tax efficiency under Italian law
- Advised a client on optimal Italian tax planning strategies involving a U.S. S-Corp with active business operations and a U.S. LLC holding a highly appreciated asset, addressing cross-border structuring and future exit consideration
- Assisted a client in preparing an EU-wide ultimate beneficial ownership package for submission to European banks in connection with anti-money laundering and know-your-client compliance reviews and investigations.
- Advised a client on the application of the EU Parent-Subsidiary Directive and the reduced withholding tax rates under the Italy–U.S. tax treaty in a complex structure involving U.S. entities (QSUB, S-Corp, LLC) with an irrevocable trust as the ultimate shareholder.
- Defended a client in a tax audit against an Italian tax residency claim by applying Italian tax law and the Italy–U.S. tax treaty, and by submitting U.S. federal and state tax filings reviewed and interpreted under the Italian tax framework, demonstrating no material Italian liability.
- Represented a high-net-worth Belgian citizen regarding the U.S. tax implications of expatriation and the taxation of U.S. retirement and deferred compensation plans.
- Represented a Cyprus-based holding company of a family office in evaluating the status of its corporate beneficial owners for U.S. FATCA reporting and treaty purposes in connection with a U.S. investment account, including assessing whether the structure raises concerns regarding the use of Cyprus as a treaty jurisdiction.