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US LLC + Italian citizenship

Zio Silvio

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Jan 31, 2025
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Hey guys,

I'll quickly explain my situation and hope to get an answe to this burning doubt I have:

- I am based in Italy.
- I am a freelancer, but work only with non-Italian companies.
- I obviously don't want to pay taxes.
- I can't get tax residency elsewhere because of family reasons.
- I am willing to take a small risk

My question is:

If I open an US LLC from Italy, with a US bank account. And never:
- Transfer money to myself or one of my EU bank accounts.
- Never declare the US LLC to the Italian governement.
- Do not invoice Italian companies.

Will the Italian governemtn automatically know about the US LLC?

I know that under FACTA only bank data is exchanged, but it doesn't affects LLC.

Is it correct?

I know it's not the cleanest solution, but because of family reaosns, I can't move my citizenship elsewhere.
 
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Reactions: Alonzo
Seems indeed purely unilateral.
It's not. It's reciprocal.
In particular, the IGA is a reciprocal agreement, meaning that Italy and the US will automatically exchange annually, on a mutual basis, specific account holder information that financial institutions in each country will report to their own competent authority as required under local law.
 
It's not. It's reciprocal.
In particular, the IGA is a reciprocal agreement, meaning that Italy and the US will automatically exchange annually, on a mutual basis, specific account holder information that financial institutions in each country will report to their own competent authority as required under local law.
Yeah, but the financial account is owned by the LLC, not myself.

Is it wrong?
 
It's not. It's reciprocal.
In particular, the IGA is a reciprocal agreement, meaning that Italy and the US will automatically exchange annually, on a mutual basis, specific account holder information that financial institutions in each country will report to their own competent authority as required under local law.
Sorry. I just woke up and misread your post. Yes, they share information in both directions.

Yeah, but the financial account is owned by the LLC, not myself.

Is it wrong?
US banks collect details about all authorised users and about UBOs. They will report you.
 
I know it's not the cleanest solution, but because of family reaosns, I can't move my citizenship elsewhere.
You do not need to move the citizenship, you need to move you.

You either need to stop working (or at least not own anything on paper and also not be the director of the company) or you need to leave Italy. All other ways are going to fail sooner or later.
 
@JohnnyDoe nice photo
Can you expand more your answer? Is the information exchanged automaitcally?
There are so many ways you can get into serious trouble with this strategy, in addition to exchange of information. Not worth trying your luck.
 
you could do that 15 years ago.... but those times are gone.
these days you are playing with fire.

And since italian tax agency sees the LLC as opaque structure, they'll charge you with all the taxes and social security as if it were a local corporation...
and the issue is that if you do decent numbers, you're pretty much always above the criminal threshold too...

they don't care if the USA see it as disregarded entity.
You could get away with it if you have a partner in the US, and office etc... a real partnership.
But if you're alone you pretty much shooting yourself in the foot and cannot really defend.

man up and relocate if you're serious about your business... you've got malta, switzerland, or even any cheap eastern europe country under 2hr flight depending on where you are in italy...
if you really want to stay in italy these days... just get a well paying job, even a remote one, and enjoy sun and pizza.
for bootstrapping a business you better leave while you can...
 
Since OP already wants to break the law, there are probably (illegal) ways to do this if he can use someone else's name.
Yes, he uses a nominee director and nominee shareholder as I proposed.
 
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