Citizenship taxation. The U.S. taxes citizens on worldwide income regardless of residence. Treaty relief and foreign tax credits matter; “moving to Italy ends IRS filing” is false.
SERP staples: US Italy tax treaty, dual tax residency Italy USA, saving clause Italy.
Tie-breakers (OECD-style sequence)
When both countries claim residence under domestic law, the convention typically applies: permanent home → centre of vital interests → habitual abode → nationality → mutual agreement.
What practitioners warn about
- The saving clause preserves many U.S. taxing rights over citizens even after Italian residence
- Foreign Tax Credit (Form 1116) is often central; FEIE may help in specific move years
- FBAR / FATCA continue; Italian Quadro RW starts with Italian residency
- Treaty-based positions may require Form 8833 disclosure when applicable
Pair with Italian tax residency, our Tax Services Italy hub, and — when U.S. and Italian rules apply together — US–Italy cross-border tax advisory.
Official & reference sources
- U.S. Treasury — Italy–United States income tax convention materials
- IRS — citizenship taxation, Foreign Tax Credit, Form 8938 themes
- Italian residency materials (art. 2 TUIR) via Agenzia delle Entrate / Normattiva