Residents or citizens of Italy who are not U.S. citizens and do not live in the U.S. will be taxed at the time of death by the U.S. only on assets located in the U.S. to include:
- Real property in the U.S.
- Certain tangible property located in the U.S.
- All debts (bonds, promissory notes and bills of exchange) from a U.S. person, government, corporation or other legal entity
- Shares in U.S. corporations
- Goodwill of a business carried on in the U.S.
- Patents, trademarks and designs registered in the U.S.
- Copyrights licensed in the U.S. 71
The applicable U.S. estate tax (but not the gift tax) can be reduced by applying a pro rata share of a $1,455,800 credit against the tax. The share of this credit is based upon the percentage that the U.S. estate bears to the entire worldwide estate determined by the following calculation:
$1,455,800 x Value of estate situated in the U.S.
Value of entire gross worldwide estate.72
The U.S. will tax all gifts of tangible property or real property located in the U.S. at the time of the gift in the same manner as gifts made by any other non-citizen not a domicile of the U.S.
Citizens of Italy who are living permanently in the U.S. will be taxed by the U.S. on the transfer by gift or at death of any assets regardless of where they are located in the world. The tax which the U.S. will impose on such transfers and the applicable exemptions and credits are those available for any non-citizen domiciled in the U.S. (See answers 4, 5 and 6.)