Italy Tax Agency Clarifies Income Tax on Value of Financial Assets for Nonresident Trust Beneficiary

The Italian Revenue Agency March 25 issued Letter No. 84/2026, clarifying income tax on the value of financial assets held abroad (IVAFE), for the beneficiary of a nonresident trust. The taxpayer, a U.S. citizen and tax resident of Italy, was the beneficiary of an irrevocable trust governed by U.S. law and didn’t own or control the trust assets. The taxpayer sought clarification on whether his status as an income-only beneficiary of the trust fell within the scope of the IVAFE. Upon review, the Tax Agency clarified that the taxpayer wasn’t subject to the IVAFE on the trust assets, because the: ...