Italy Tax Agency Clarifies Tax Treatment of Nonresident Trust, Resulting Asset-Monitoring Obligations

The Italian Revenue Agency March 18 issued Letter No. 81/2026, clarifying the tax treatment of a nonresident trust and the resulting asset-monitoring obligations. The taxpayer, a nonresident primary beneficiary of an irrevocable trust governed by U.S. law, planned to transfer his tax residence to Italy in 2026. The taxpayer sought clarification on whether the U.S. trust qualified as an autonomous taxable entity rather than an interposed trust and whether he would be excluded from tax-monitoring obligations and specified foreign-asset wealth taxes upon the tax residency transfer. Upon review, the Tax Agency clarified that: 1) the U.S. trust qualified as an ...