Exit Tax 2027: what the proposal provides for those who want to move to the USA
Moving to the United States requires planning that also includes estate and tax residency. The exit tax proposal contained in the 2027 Budget bill adds an element to consider before defining the timing and modalities of the transfer.
Updated as of November 4, 2026. This article describes a legislative proposal, which may change during parliamentary consideration.
What the proposal provides
The 2027 Budget bill proposes introducing an exit tax for certain natural persons who transfer their tax residence outside Italy. The mechanism would apply to income earned from certain financial activities even when these have not been sold. These are the so-called latent gains: the positive difference between the value of the asset at the date stipulated by the rule and the related tax-recognised cost. The point to understand is this: the transfer could become fiscally relevant even without a sale of the investments. However, the proposal should not be read as a tax automatically applicable to anyone leaving Italy.
Who might be interested
In the text examined, the application to natural persons requires the simultaneous presence of several conditions:
Italian tax residence for at least six of the last ten tax periods preceding the transfer; loss of Italian tax authority over the affected income due to the transfer; total normal value of the relevant assets and rights of at least 800,000 euros.
The proposed procedure applies to those individuals whose loss of Italian tax residency takes effect from January 1, 2027. To determine whether a person falls under the rules, it is necessary to examine their tax history, the composition of their investments, and the effects of the transfer to the country of destination.
Threshold of 800,000 euros and rate of 26%: two different concepts
The threshold of 800,000 euros would serve to define the scope of application of the measure. The text examined concerns the Overall normal value of the relevant assets, Instead of their historical cost. The taxable base would instead be determined by the sum of the positive differences between the value of the individual assets and rights and the tax-recognised cost thereof, according to the provisions provided for. The ordinary rate indicated in the analyses of the proposal is 26%, with specific treatments for certain categories of financial instruments. Therefore, it is not correct to apply 26% indiscriminately to the entire portfolio. The presence of investments in loss also requires attention: it must not be assumed that these can automatically compensate for all latent capital gains.
Why the topic matters for those who move to the United States
For those planning a move to the USA, the issue mainly concerns the coordination between the Italian tax position on departure and the American one on arrival. Before setting a date, it is useful to review the following:
the years of Italian tax residency; the financial activities and holdings; the related tax-recognised costs; the potential capital gains generated; the moment when Italian tax residency would cease; the moment when US tax obligations would begin.
The possible recognition in the USA of the tax values and taxes paid in Italy must be examined specifically. It should not be assumed that the payment of a tax in one country automatically resolves all consequences in the other.
Would it be possible to postpone the payment?
The text examined provides, as a general rule, for payment within 180 days from the date when the loss of tax residence takes effect. It also contemplates an option for deferral for transfers to certain countries, subject to conditions. These include a 50% advance payment and an appropriate guarantee. For non-EU countries, the proposal requires agreements that allow for both an adequate exchange of information and assistance in recovering tax debts with the characteristics specified by the standard.For a transfer to the United States, access to the deferral must therefore be specifically verified. The mere existence of a tax information exchange does not allow it to be taken for granted.
How to prepare without making hasty decisions
The first step is to collect reliable documentation: extracts of investments, dates and purchase costs, documents on holdings and information on the tax residence of previous years. The second is to jointly assess the Italian and US positions, considering the liquidity that may be required. Sales, donations, transfers or changes in the ownership of investments can have their own consequences. They must be examined before being used within a transfer strategy. The calendar also requires attention: the date of travel, the visa and the AIRE registration, considered individually, do not exhaust the analysis of tax residence.
The support of Link2America
A project of relocation to the United States involves personal, professional, entrepreneurial, and patrimonial decisions that must be made in a coherent manner. Link2America assists entrepreneurs and professionals in planning the US project and in coordinating operational activities with the involved tax and legal professionals.Are you considering a transfer to the United States in 2027?
Contact Link2America to frame the project and identify the necessary details before defining the operational timeline.
The content is for informational purposes only and does not constitute tax or legal advice. The application of the measure will depend on the final text being approved and on the individual situation.
Frequently asked questions about the 2027 Exit Tax
Is the Exit Tax 2027 already a final law?
As of November 4, 2026, the measure described is contained in the Draft Budget 2027. The text may change during parliamentary scrutiny.
Who would move to the USA automatically pay 26%?
No. The proposal sets out specific requirements related to the previous Italian tax residence, the value of the assets involved, and the loss of Italian tax authority. The position must be assessed on a case-by-case basis.
The 800,000 euros refer to the cost of purchasing the investments?
In the text examined, the threshold concerns the total value of the assets and rights relevant at the date identified by the proposal. The tax-recognised cost, on the other hand, is used to determine capital gains.
Will the tax affect all assets?
The proposal concerns certain financial income and the related capital gains generated. Its scope does not automatically coincide with the entire personal wealth.
Could there be a tax even without selling the securities?
Yes. The proposed mechanism takes into account the capital gains generated and not yet realized on the affected assets.
Can someone who moves to the United States defer payment?
This is a point that needs to be specifically verified. For countries outside the EU, the text requires agreements on the exchange of information and on assistance in recovering tax debts, in addition to the other conditions provided for.
Do I have to register with the AIRE by 2026?
The AIRE registration alone does not resolve the analysis of tax residency. The actual situation and the applicable rules in both countries must be evaluated.