In its ruling n. 21614 of October 26, 2016 Italy’s Supreme Court considered the issue of the application of the gift tax upon the transfer of property to a trust. The issue arises under the provisions of Law n. 262 of October 3, 2006, which reinstated the gift tax. Article 2 of Law 262, at
taxation
Italy’s Tax Provisions on Trusts – Updated
By Marco Rossi on
Italy operates specific provisions on tax treatment of trusts. Trusts formed under foreign law are recognized and enforced in Italy pursuant to the Hague Convention on Trusts dated July 1, 1985. To the extent they have Italian assets, or Italian grantor, trustees or beneficiaries or Italian source income, foreign trusts may be subject to Italy’s…
2012 New Self-Reporting Requirements For Foreign Financial Assets
By Marco Rossi on
Starting with the tax year 2011, the new IRS Form 8938 must be filed by all U.S. persons if total foreign financial assets exceeded $50,000 at any point during the year. Form 8938 will be in addition to the long-standing Treasury Department FBAR (Foreign Bank and Financial Accounts Report) required for financial assets abroad that…
Interview with MQR&A on Italian financial newspaper Italia Oggi
By Marco Rossi on
An interview on Marco Q Rossi & Associati has been published today on the Italian financial newspaper ITALIA OGGI. We attach below the file with the full account: www.lawrossi.com/images/stories/docs/MQR_Italia_Oggi.pdf
Italy’s Tax Administration Issued Additional Clarifications on Italian Taxation of Trusts
By Marco Rossi on
Italy’s Tax Administration provided additional clarifications on Italian taxation of trusts. In particular, Circular n. 61/E issued on December 27, 2010 addresses the situations in which a trust is disregarded as abusive or fictitious interposition between the settlor and the assets and income of the trust and must be disregarded for tax purposes. Circular 61/E expanded the list of examples of abusive situations and shows the administration’s willingness to contrast the use of trusts for tax avoidance purposes.…