Tax Treaties and Competent Authority Procedures
Tax treaties play a critical role in avoiding double taxation and allocating taxing rights between countries. Both the U.S. and Italy maintain extensive treaty networks that can provide meaningful relief from withholding taxes, double taxation, and disputes over permanent establishments. Yet the rules are highly technical, vary from treaty to treaty, and often lead to complex disagreements with tax authorities. We help clients understand, claim, and defend their treaty benefits while ensuring compliance with all related reporting obligations.
Attorneys
Our attorneys counsel individuals and businesses on interpreting and applying U.S. and Italian tax treaties, advising on eligibility for treaty benefits, structuring operations to reduce withholding taxes, and addressing disputes over permanent establishment or profit attribution. When conflicts arise, we assist clients in pursuing relief through the Competent Authority process, coordinating directly with U.S. and Italian tax authorities.
In partnership with Marco Q. Rossi & Associati (Of Counsel) we provide clients with coordinated treaty planning and dispute resolution strategies that protect against double taxation and preserve cross-border investment value.