Almost all countries in the world impose taxes on economic activity. These fees are of a different nature: local, national or federal on property, while national or federal on corporate income.
The goods that you will buy through us are immovable. These properties will be purchased not by you personally, but through a company you will be 100% shareholder. Obviously, you will be free to address the property of the company to a third person you mention. We do not recommend purchasing on a personal basis as the tax is higher and you would also be subject to double taxation in Italy. Also, the benefits you can access using your American company, which represent a good slice of the gain, would be de facto vanished.
The Convention of 25/08/1999 was signed by the Italian and US governments to avoid double taxation on income taxes and to prevent fraud or tax evasion. In this Convention we read (Article 7) that “the profits of a company in a Contracting State are taxable only in that State”: the profits of the company that we will open will be taxed only in the United States. Whereas (Article 10) “dividends paid by a resident of a Contracting State to a resident of the other Contracting State are liable to tax in that other State”, which means that the dividend charges you have to pay in Italy. If you also have to pay some of the dividends in the United States, this part will be discounted by what you have to pay to the Italian government. Presence coins (Article 16) should also be declared in Italy.
Always according to the Convention, your company will have the characteristics of trading in the United States, renting property, and any benefits (Article 22 – Other Income) that the Company will decide upon to perform your Manager or Director will only be considered in the United States. In the United States, so-called benefits are considered as fully downloadable instrumental charges.
The IMU on overseas homes is called IVIE. Article 19, paragraph 13 and following of Decree 201/2011 (Law 214/2011) governs the taxation of immovable property located abroad. This tax affects all residents in Italy (Italian citizens, foreign nationals, both Community and non-EU citizens) who own or hold for other rights, such as usufruct, overseas property. But you will not be the owner of houses abroad so you will not be subject to this tax. The real owner of homes will be a company (LLC or Corporation) that we will help you to open. As already mentioned, of course, you will be the only shareholder of this company, or you will be the one who will be the one who will be called. American society is actually and lawfully obliged to pay only the taxes of the country in which it was established and in which it operates.
Your investment every month will venerate earnings that will accumulate on your corporate account and, when and if you want, you, as a director or manager, will determine whether or not the company should break a coupon of profits for members . On this coupon, which the company will pay to the shareholders, obviously you will pay a tax. The board of directors of the company, made up of the manager or the director, will then decide whether to attribute or not benefits and to whom to attribute them.
In the USA you will pay:
• local taxes,
• federal taxes net of expenses incurred by the company (taxes are paid on the gain and not on sales)
In Italy you will pay:
• dividend taxation deducted from the possible withdrawal in the United States.
When we estimate net earnings, this percentage is always referred to excluding federal taxes and Italian taxation. It will be the task of the accountants who will assist you in these two countries to help you and offer support in optimizing your tax burden. The US Accountant we provide you free of charge, included in the annual management package, you will obviously be free to change it at your convenience and at your own expense, while the professional in Italy is at your expense.
This is in any case an investment in real estate income. Just like in Italy, even in the United States, you will be held as an owner of the property to fulfill any repairs that will be necessary from time to time in the ordinary and / or extraordinary management of the property.
In any case, if you need it, we will be happy to tell you about our highly-trained Italian professionals who work with us and who can help you optimize your tax burden.
Warning: We will not suggest how to evade taxes, just our professionals, if possible, will help you optimize your tax burden and then pay as little as possible while remaining in full legality!