Italy’s Revenue Agency has ruled that a Delaware trust — irrevocable, run by an independent professional trustee, with no other strings attached to the settlor or main beneficiary — is nonetheless fiscally “interposed,” triggering full income tax, RW monitoring, IVIE and IVAFE exposure for the beneficiary once she moves to Italy. The reason: a standard US-law clause giving her the power to decide, by will, how the remaining trust assets are split among her own children after she dies. Ruling No. 81/2026 treats that future, death-triggered choice as present control over the trust’s assets today — a reading of the “genuine divestment” test that looks hard to square with how limited powers of appointment actually work, and one that, if generalized, would make interposition the default outcome for a huge share of ordinary US discretionary trusts.…