Taxation of Outbound Investments and Activities
U.S. and Italian taxpayers with investments or business operations abroad face the challenge of taxation in both the host country and their home country, exposing them to the risk of double taxation. To manage these risks, taxpayers must structure foreign investments carefully and make full use of foreign tax credit provisions in the U.S. and Italian tax codes. We counsel clients on planning outbound investments in ways that minimize global tax burdens, maximize available credits and exemptions, and ensure compliance with anti-deferral and anti-abuse rules.
Attorneys
Our attorneys advise businesses, investors, and families on the tax treatment of outbound investments and foreign operations under both U.S. and Italian law. We guide U.S. clients through foreign tax credit rules, Subpart F, PFIC, and controlled foreign corporation (CFC) provisions, while advising Italian taxpayers on participation exemptions, controlled foreign company rules, and anti-inversion rules. We also assist with profit repatriation strategies, treaty-based planning, and compliance reporting for controlling interests in foreign entities.
In partnership with Marco Q. Rossi & Associati (Of Counsel) we provide coordinated U.S.-Italy counsel that helps clients structure cross-border investments to achieve maximum efficiency while avoiding costly tax pitfalls.