In a landmark ruling issued in January 2023, the Italian Supreme Court (Corte di Cassazione) held that US Individual Retirement Accounts (IRAs) are exempt from Italian taxation on any gains. This is a significant victory for US citizens who are residents of Italy, as it will help to avoid double taxation on their IRAs.

The ruling was based on a 1999 US-Italy tax treaty, which provides that US citizens who are residents of Italy are not subject to Italian taxation on income from US sources, including income from IRAs. The Italian tax authorities had argued that this exemption did not apply to IRAs, but the Supreme Court disagreed.
The Supreme Court's ruling is a positive development for US citizens who are residents of Italy. It will help to reduce the burden of double taxation, and it will make it more attractive for US citizens to live and work in Italy.
Here are some of the key takeaways from the Supreme Court's ruling:

• US citizens who are residents of Italy are not subject to Italian taxation on any gains in their US IRAs.
• This exemption applies to both traditional and Roth IRAs.
• The exemption is based on the 1999 US-Italy tax treaty.
• The Italian tax authorities cannot override the provisions of the tax treaty.

If you are a US citizen who is a resident of Italy, you should consult with a tax professional to discuss how the Supreme Court's ruling affects you."