The tax decisions that come before the return.
What you pay in the United States depends far less on how you fill in the return and far more on how the company was built, how profits move and how dealings with the parent company are set up. These are choices made at the start and painful to correct later.
What it covers
Legal form and taxation
Corporation, LLC, branch: each is taxed differently in the United States and in Italy. We look at the impact on the whole group, not only the US side.
The Italy–US treaty
Applying the double taxation treaty: withholding on dividends, interest and royalties, foreign tax credits and the documentation needed to claim them.
Repatriating profits
How to bring the results of the US entity back to Italy — dividends, compensation, intercompany services — choosing the route that costs least and holds up over time.
Intercompany dealings
Transfer pricing, service agreements and loans between parent and subsidiary, set up so they stand up in front of both tax administrations.
Planning ahead costs less than fixing it later.
US structures put together in a hurry are easy to spot: a legal form chosen on hearsay, profits stuck because repatriating them would cost too much, intercompany contracts written after the fact. They can be put right, but it takes time and usually tax already paid that never comes back.
We would rather step in earlier, while the options are still open, and think in terms of years: what you want to do in the United States, with whom, and how the result should come back to Italy.