Taxation of Business Income and Permanent Establishment Issues
Foreign businesses operating in Italy or the United States face complex rules that determine when their presence becomes taxable. In Italy, the concept of “permanent establishment” can trigger corporate tax obligations based on physical presence, agents, or regular business activity. In the U.S., foreign taxpayers engaged in a “trade or business” are subject to tax on income “effectively connected” with those activities. We help clients identify, plan for, and comply with these rules to avoid inadvertent tax exposure and manage their obligations effectively.
Attorneys
Our attorneys counsel companies and individuals on the taxation of business income and permanent establishment issues in Italy and the United States. We advise on whether activities rise to the level of a permanent establishment or U.S. trade or business, and we assist in preparing the required filings, international information returns, and federal or state tax submissions.
In partnership with Marco Q. Rossi & Associati (Of Counsel) we deliver coordinated guidance for clients with cross-border operations in both jurisdictions, ensuring they remain compliant while structuring their activities to reduce unnecessary tax burdens.
Marco Q Rossi & Associati
Marco Q. Rossi & Associati PLLC, Of Counsel — International Tax and Italian Business & Tax Law
Through Marco Q. Rossi & Associati, we maintain an office in Miami that allows us to serve clients seamlessly in Florida while expanding our international reach.
Marco brings deep expertise in U.S. tax law, international (particularly Italian) law, and estate planning, making him an invaluable resource for our clients with cross-border interests.