Interested in training for your team? Click here to learn more

Italy and France--U.S. Dual Taxation Issues: U.S. Treaty Benefits, Saving Clause, Residency Rules

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

This program is included with the Strafford CPE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Thursday, May 23, 2024

Recorded event now available

or call 1-800-926-7926

This webinar will discuss the dual taxation issues that advisers, including multinational advisers, must address for taxpayers traveling and residing in France and Italy, as well as the U.S. Our seasoned foreign tax advisers will explain residency, totalization agreements, and taxation of passive and earned income for these countries. They will also point out tax-saving devices, including foreign tax credits, foreign earned income and housing exclusions, and the application of treaty benefits.

Description

Unlike other countries, the U.S. taxes the worldwide income of its residents regardless of where they reside and earn their living. In Italy and France, having a residence in the country can establish residency. Similar to the U.S., both countries have their unique 183-day tests for residency. A U.S. citizen living abroad could meet the U.S. and Italy or France residency requirements within the same tax year. For this reason, the U.S. income tax treaties with Italy and France contain tie-breaker rules to settle this issue.

Although nonresidents' passive income is generally subject to a 30 percent tax rate, the treaties with France and Italy provide exemption from or lower rates for certain types of passive income. These benefits, though, do not extend to U.S. residents by virtue of the saving clause included in U.S. income tax treaties. The saving clause preserves the right of the U.S. to tax its citizens regardless of the benefits available in these treaties. Although the agreements differ, the U.S. has totalization agreements with France and Italy to eliminate dual coverage and payments of self-employment or social security taxes. Multinational tax advisers working with taxpayers who reside or work in Italy or France as well as the U.S. need to understand the rules of taxation for these countries.

Listen as our panel of multinational tax specialists explains how the U.S., Italy, and France tax intercontinental travelers.

READ MORE

Outline

  1. Italy and France: U.S. dual taxation issues introduction
  2. Residency
    1. Italy
    2. France
  3. Totalization agreements
    1. Italy
    2. France
  4. Treaty benefits and caveats
  5. Inheritance taxes
    1. Italy
    2. France
  6. I. Tax-saving devices
    1. Foreign tax credits
    2. Foreign earned income exclusion
    3. Housing exclusion
  7. Best practices

Benefits

The panel will cover these and other critical issues:

  • How the saving clause can supersede lower treaty tax rates
  • Residency requirements for taxpayers living or working in Italy
  • How the U.S. France totalization operates
  • Tax-saving vehicles for multinational taxpayers including foreign tax credits

Faculty

Diosdi, Anthony
Anthony V. Diosdi
Partner
Diosdi & Liu

Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax...  |  Read More

Access Anytime, Anywhere

CPE credit is not available on downloads.

CPE On-Demand

See NASBA details.