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Old 09-15-2005, 12:50 AM
A.G. Kalman
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Default Re: international tax treaty USA-Italy

outmarcus[at]gawab.com wrote:

- quote -

> Hello,
> I am professional italian athlete that sometimes win race'
> prizes in USA races. Does exist an international treaty (or
> similar) between USA and Italy that regulate how an italian
> resident can avoid the double taxation (in USA + in Italy)
> of USA occasional income?


Yes there is a tax treaty between Italy and the U.S.A.
Article 17 covers entertainers and athletes. Below is a
relevant excerpt that explains when your prize money would
be taxable by the U.S.A. Basically it says that the U.S.A.
will tax your income if it exceeds $12,000 for the year or
if you are physically present in the U.S.A. for more than 90
days in the year. There is a new proposed treaty between the
two nations that increases the amount to $20,000 but I do
not believe that it has gone into force. If you do have to
pay tax to the U.S.A., and Italy also plans to tax your
income, Italy should provide some form of foreign tax credit
to you for the taxes paid to the U.S.A. per Article 23,
Relief from Double Taxation.

1. Notwithstanding the provisions of Articles 14
(Independent Personal Services) and 15 Dependent Personal
Services) income derived by a resident of a Contracting
State as an entertainer, such as a theatre, motion picture,
radio, or television artiste, or a musician, or as an
athlete from his personal activities as such exercised in
the other Contracting State may be taxed in that other
State, if:

a) the amount of the gross receipts derived by such
entertainer or athlete, including expenses reimbursed to him
or borne on his behalf, from such activities exceeds twelve
thousand United States dollars ($12,000) or its equivalent
in Italian lire for the fiscal year concerned; or

b) such entertainer or athlete is present in that other
State for a period or periods aggregating more than 90 days
in the fiscal year concerned.

--
Alan
http://taxtopics.net

<< ================================================== ===== > << The foregoing is intended for educational purposes only > << and does NOT constitute legal OR professional advice. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2005) - All rights reserved. > << ================================================== ===== >
  #-1  
Old 09-13-2005, 07:09 AM
outmarcus@gawab.com
Guest
 
Posts: n/a
Default international tax treaty USA-Italy

Hello,
I am professional italian athlete that sometimes win race'
prizes in USA races. Does exist an international treaty (or
similar) between USA and Italy that regulate how an italian
resident can avoid the double taxation (in USA + in Italy)
of USA occasional income?

Thanks,
Mary

<< ================================================== ===== > << The foregoing is intended for educational purposes only > << and does NOT constitute legal OR professional advice. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2005) - All rights reserved. > << ================================================== ===== >
 

Tags
international, tax, treaty, usaitaly
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