ItalyUnited States
The buyer’s guide

Italy and the United States: two ways of buying a home.

The same word, “closing”, hides two different worlds. This guide sets them side by side, for Americans buying in Italy and for Europeans buying in New York.

1notary in Italy, neutral, instead of two attorneys
2commissions in Italy: buyer and seller both pay
2–4%of the price per year to keep a Manhattan condo, before any mortgage
$60kUS estate-tax exemption for non-resident foreigners
At a glance

Eight differences that change everything.

For the United States we refer to New York, where our company is based. Rules vary from State to State.

Who runs the closing

ItalyA notary: a neutral public official

United States · New YorkTwo attorneys, one per side, plus a title company

The agent

ItalyA neutral mediator between the parties

United States · New YorkRepresents one side, with fiduciary duties

Commission

ItalyPaid by both buyer and seller

United States · New YorkTraditionally paid by the seller and shared

When the deal becomes binding

ItalyAt acceptance of the written offer

United States · New YorkOnly when both sign the contract

Deposit

Italy10–20%, usually paid to the seller

United States · New York10%, held in attorney escrow

Building approval

ItalyNone

United States · New YorkCo-op board can refuse a buyer

Main tax on purchase

ItalyRegistration tax on cadastral value, or VAT

United States · New YorkMansion tax from $1M; transfer taxes on the seller

Title protection

ItalyPublic registers and notary’s liability

United States · New YorkTitle insurance

In depth

Nine chapters. Open the one you need.

01

Who can buy

Rights of foreign buyers, visas, and how to hold the property.

Can a foreigner buy?

ItalyYes. US citizens buy on the same terms as Italians under the principle of reciprocity. The only prerequisite is an Italian tax code (codice fiscale), issued free of charge by the tax office or an Italian consulate.
United States · New YorkYes. There is no federal restriction on foreigners owning residential property and no residency requirement. In practice the filter is the building: many co-ops are reluctant to approve buyers whose income and assets are abroad.

Does buying give a right to stay?

ItalyNo. Ownership gives no visa. US citizens may stay 90 days in any 180 in the Schengen area; longer stays need a visa, most often the elective residence visa for people with stable passive income.
United States · New YorkNo. Owning a home does not create immigration status. Italian citizens normally visit under the Visa Waiver Program (ESTA) for up to 90 days per trip, or with a B-2 visa for longer stays.

In whose name?

ItalyAlmost always personally. Buying through a company is possible but loses the main-residence tax benefits and changes the tax treatment of a future sale.
United States · New YorkForeign buyers frequently use an LLC or a trust, for privacy, liability and above all estate-tax planning. Condos accept this easily; most co-ops do not.

Paperwork to prepare

ItalyPassport, codice fiscale, and preferably an Italian bank account. Every payment must be traceable: cheques and transfers are listed one by one in the deed.
United States · New YorkPassport, proof of funds and bank references with the offer. A US tax number (ITIN) is needed sooner or later. All-cash purchases through companies are subject to federal anti-money-laundering reporting of the real owners.
02

How real estate agents work

Neutral mediator versus exclusive representative; who pays the commission and when.

The agent’s role

ItalyThe Italian agent is a mediatore: by law (Civil Code, art. 1754) an impartial intermediary who brings the parties together and must disclose to both every circumstance he knows that affects the deal. He must be registered with the Chamber of Commerce and insured.
United States · New YorkThe agent is a fiduciary of one side. The listing broker works for the seller; the buyer’s broker works for the buyer. Acting for both (dual agency) requires informed written consent. Licences are issued by each State.

How listings circulate

ItalyThere is no national shared database. A property can be given to one agency exclusively or to several at once, and much of the best stock never reaches the portals. The right local agent matters more than the search engine.
United States · New YorkListings are shared. Through the MLS, or in New York City the REBNY listing service, an exclusive listing is available to every member broker, who can bring a buyer and share the fee (co-brokerage).

Who pays the commission

ItalyBoth. Buyer and seller each pay the agency, typically 2–4% of the price plus 22% VAT each. The amount is agreed in writing in the offer or the mandate.
United States · New YorkTraditionally the seller pays a single fee of about 5–6%, split between the two brokers, so the buyer pays nothing directly. Since 2024 the buyer’s broker fee must be agreed separately and in writing; in New York it is still most often paid by the seller.

When it is earned

ItalyAt the “conclusion of the deal”: when the accepted offer or preliminary contract becomes binding, not at the final deed. This surprises many foreign buyers.
United States · New YorkAt closing, paid out of the sale proceeds. No closing, no commission.

The other professionals

ItalyThe notary, chosen and paid by the buyer, is central. A surveyor or architect verifies planning and cadastral compliance. A lawyer is optional for Italians and strongly advisable for foreign buyers.
United States · New YorkIn New York each party hires a real estate attorney who negotiates the contract and performs due diligence. A title company insures ownership. A US “notary public” only witnesses signatures: no relation to the Italian notaio.
03

From offer to keys

The steps, what is binding and when, deposits and timing.

The offer

ItalyA written, signed proposal (proposta irrevocabile) valid for a set number of days, usually with a deposit cheque. Once the seller accepts, it is a binding contract.
United States · New YorkIn New York an offer is made by email through the brokers and binds no one. Even an “accepted offer” is not a contract: until both parties sign, the seller may still take a higher bid.

The contract and the deposit

ItalyThe preliminary contract (compromesso) fixes price, date and conditions. The deposit (caparra confirmatoria) is usually 10–20%: a buyer who withdraws loses it, a seller who withdraws returns double.
United States · New YorkThe seller’s attorney drafts the contract of sale and the buyer’s attorney negotiates it. On signing, the buyer pays 10%, held in the seller’s attorney’s escrow account. Financing and board approval can be made conditions.

Due diligence

ItalyBest done before the preliminary: ownership and mortgages, cadastral and planning compliance, building permits, unpaid condominium charges, energy certificate (APE). The notary checks title and liens; a technician checks the building.
United States · New YorkThe buyer’s attorney reads the building’s financial statements, board minutes and offering plan, and orders a title search. A physical inspection is standard for houses and optional for apartments.

The closing

ItalyThe final deed (rogito) is signed before the notary, who reads it aloud, collects the taxes and registers the transfer. A buyer who does not speak Italian needs a bilingual deed or an interpreter, or signs through a power of attorney.
United States · New YorkA meeting of attorneys, lender and title company. Funds move by wire. For a condo the deed is recorded; for a co-op the buyer receives a share certificate and a proprietary lease.

How long it takes

ItalyTypically two to four months from accepted offer to deed, and the date is freely negotiable.
United States · New YorkAbout 60–90 days from signed contract for a condo; three to four months for a co-op, because of the board process.

Buying without travelling

ItalyYes, through a special power of attorney signed before a US notary public and legalised with an apostille.
United States · New YorkYes. A power of attorney is routinely accepted and remote closings are common.
04

Ownership and types of building

What you actually own, who must approve you, and the rules of the building.

What you own

ItalyThe apartment itself, in full ownership, plus a share of the common parts measured in thousandths (millesimi). The condominio is not a company: it is simply the co-ownership of the common parts, governed by the Civil Code.
United States · New YorkIt depends. In a condo you own real property, with a deed. In a co-op, the prevailing form in Manhattan’s older buildings, you own shares in a corporation that owns the building, with a lease on your apartment.

Does anyone approve the buyer?

ItalyNo. Neighbours and administrators have no say. The only exceptions are specific legal pre-emption rights, for example the State’s on heritage-listed buildings.
United States · New YorkIn a co-op, yes: a detailed financial application and an interview, and the board may refuse without giving a reason. A condo board has only a right of first refusal, rarely used.

Who runs the building

ItalyThe owners’ meeting (assemblea) decides; a professional administrator is mandatory when there are more than eight owners. Rules are set by the building regulations.
United States · New YorkAn elected board, assisted by a managing agent and often resident staff. House rules can be detailed, from renovations to pets.

Renting it out

ItalyGenerally free. Short lets require a national identification code (CIN) and compliance with local rules; some building regulations restrict them.
United States · New YorkCondos are flexible. Co-ops often limit or forbid subletting and pied-à-terre use. New York City bans most rentals under 30 days unless the host lives in the home.

Other forms to know

ItalyBare ownership with a life interest (nuda proprietà and usufrutto), and heritage-listed properties, which carry restoration constraints but also tax advantages.
United States · New YorkTownhouses owned outright, “condops”, buildings on leased land, and new developments sold by a sponsor under an offering plan filed with the State Attorney General.

How size is measured

ItalyIn square metres of “commercial surface”, which includes walls and a percentage of balconies and cellars. Homes are described by number of rooms (locali), kitchen included or not depending on the region.
United States · New YorkIn square feet (1 m² = 10.76 sq ft), and by bedrooms and bathrooms. Condo figures often include wall thickness; co-ops frequently have no official figure at all.
05

Taxes and costs when you buy

What to add to the price on each side of the Atlantic.

Buying from a private seller

ItalyRegistration tax of 9% as a second home, or 2% as a main residence if you move your residency there within 18 months. It is calculated on the cadastral value, usually well below the price, plus €100 in fixed taxes.
United States · New YorkNo general purchase tax, but New York’s “mansion tax” applies from $1 million: 1% of the price, rising in steps to 3.9% at $25 million and above. It is paid by the buyer.

Buying new from a developer

ItalyVAT on the full price: 10% as a second home, 4% as a main residence, 22% for luxury categories, plus €600 in fixed taxes.
United States · New YorkIn new developments the buyer customarily also pays the transfer taxes that would normally fall on the seller, and the sponsor’s attorney fee. This is negotiable.

Taxes paid by the seller

ItalyNone on the transfer itself. Only a possible capital gain is taxed (see Taxes).
United States · New YorkNew York City transfer tax of 1% up to $500,000 and 1.425% above, plus New York State transfer tax of 0.4%, or 0.65% from $3 million.

Notary, attorney and title

ItalyThe notary’s fee is scaled to value, typically a few thousand euros, and covers title searches and registration. Title insurance is not used.
United States · New YorkAttorney’s fees are typically a few thousand dollars. Title insurance for a condo or house costs roughly 0.4–0.5% of the price; co-ops need only a lien search.

If you take a mortgage

ItalyA substitute tax of 0.25% of the loan for a main residence or 2% for a second home, plus the bank’s fees and the notary’s mortgage deed.
United States · New YorkIn New York City a mortgage recording tax of about 1.8% of the loan under $500,000 and 1.925% above, for condos and houses. Co-op loans are exempt.

A realistic budget

ItalyFor a second home bought from a private seller, allow roughly 10–15% on top of the price including the agency fee; less where the cadastral value is low.
United States · New YorkFor a condo bought in cash, roughly 2–4% on top of the price; more with a mortgage or in a new development, and above the mansion-tax thresholds.
06

Running costs and extra charges

Annual property taxes, building charges and the fees people forget.

Annual property tax

ItalyIMU on second homes: around 0.76–1.06% of a cadastral tax base, set by each municipality, so usually modest. A non-luxury main residence is exempt.
United States · New YorkProperty tax based on assessed value, generally much higher than in Italy. Condo owners are billed directly; in a co-op it is included in the monthly maintenance.

Building charges

ItalyUsually modest, divided by thousandths. Ordinary costs (cleaning, lift, administrator) are distinct from extraordinary works voted by the owners, which fall on the owner.
United States · New YorkMonthly common charges (condo) or maintenance (co-op) are a major item: they pay for doormen, staff, amenities and, in co-ops, the building’s own mortgage and taxes. Special assessments are possible.

How much per year, in proportion

ItalyProperty tax and building charges together are normally a small fraction of the property’s value each year. A second home in Italy is light to keep.
United States · New YorkCount on roughly 2–4% of the purchase price every year for a Manhattan condo, before any mortgage: common charges plus real estate tax. Full-service buildings with hotel-style amenities can reach 5–6%.

The second-home surcharge

ItalyNone. A second home pays IMU and nothing more; there is no surcharge for owners who live elsewhere.
United States · New YorkNew in 2026. New York City applies an annual surcharge to condos and co-ops that are nobody’s primary residence, when the City values them at $1 million or more: 4%, 5.25% or 6.5% depending on the band, calculated on the City’s own assessed market value, not on the purchase price. A unit rented to a tenant who lives there is exempt. First bills: January 2027.

Waste, utilities, insurance

ItalyWaste tax (TARI) and utilities. The building is insured through the condominium; a personal home policy is optional but sensible.
United States · New YorkUtilities, partly included in the charges in some buildings. Homeowner’s insurance is normally required by the building or the lender.

Fees people forget

ItalyVery few: the agency’s VAT, the translator or interpreter at the deed, and the technician’s compliance report.
United States · New YorkSeveral: a co-op “flip tax” on resale (often 1–3%), application and move-in fees, and in new developments a working-capital contribution of about two months’ charges.
07

Mortgages and currency

Borrowing as a non-resident, and the exchange-rate question.

Mortgages for non-residents

ItalyAvailable from a limited number of banks, typically up to 50–60% of value, with translated income documents and a slower process. Many foreign buyers pay cash.
United States · New York“Foreign national” loans exist, usually with 30–40% or more down, higher rates and cash reserves. Co-ops often demand a larger down payment and liquidity after closing.

Currency

ItalyPrices and taxes are in euros. Between offer and deed the exchange rate can move by several points: agree the transfer strategy before you sign.
United States · New YorkEverything is in US dollars, wired through the attorneys’ accounts. The same exchange-rate planning applies in reverse.
08

Taxes on rent, resale and inheritance

The three moments when the taxman returns, and how the two systems interact.

Rental income

ItalyTaxed in Italy. Individuals can choose a flat tax (cedolare secca) of 21% on residential rents, with a higher rate on additional short-let units. US citizens also report the income in the US and claim a credit for the Italian tax.
United States · New YorkA non-resident owner files a US return. By electing to be taxed on net income you deduct expenses and depreciation; otherwise 30% is withheld on gross rent. New York State tax also applies.

Capital gain on resale

ItalyFor individuals the gain is tax-free in Italy after five years of ownership. Within five years it is taxed, with an optional 26% substitute tax paid through the notary. US citizens remain taxable in the US on the gain.
United States · New YorkFederal tax on long-term gains of generally 15–20%, plus State tax. Under FIRPTA the buyer withholds 15% of the gross price when the seller is foreign, credited against the final tax.

Inheritance

ItalyLight: 4% for spouse and children above an allowance of €1 million each, plus 3% in property transfer taxes. Italian forced-heirship rules can be avoided by choosing your national law in a will.
United States · New YorkThe critical point for Italians. A non-resident foreigner has a federal exemption of only $60,000 on US property, with rates up to 40%. The Italy–US estate tax treaty and the right ownership structure can reduce this sharply: plan before buying.

Avoiding double taxation

ItalyAn income tax treaty between Italy and the US is in force. US citizens are taxed on worldwide income, so Italian property goes on the US return, with foreign tax credits, and Italian bank accounts must be reported.
United States · New YorkItalian residents declare the US property in their Italian return (quadro RW) and pay IVIE, a 1.06% annual tax on foreign property, reduced by property taxes paid in the US.
09

Protections and pitfalls

How each system protects the buyer, and where the surprises usually are.

Who guarantees ownership

ItalyPublic property registers and the notary, who is personally liable for the title searches and for registering the deed.
United States · New YorkTitle insurance: a one-off premium that covers the owner against defects in title for as long as they own the property.

What the seller must disclose

ItalyThe seller declares cadastral and planning compliance in the deed and must hand over the energy certificate. Hidden defects are covered by a statutory warranty; off-plan purchases are protected by a bank guarantee on deposits and ten-year insurance.
United States · New YorkLargely “buyer beware”. New York requires a property condition disclosure statement for one-to-four family homes, but for apartments the protection is the attorney’s due diligence and, in new developments, the offering plan.

Where your deposit sits

ItalyNormally with the seller. Registering the preliminary contract through a notary, or using the notary’s escrow account, protects the buyer if something goes wrong before the deed.
United States · New YorkIn the seller’s attorney’s escrow account until closing, released only under the terms of the contract.

Typical surprises

ItalyWorks carried out without permits, floor plans that do not match the cadastral records, heritage constraints, and the agency fee falling due at the preliminary stage.
United States · New YorkA co-op board rejection after months of work, special assessments, buildings on leased land, flip taxes, and tax abatements about to expire.

This guide gives general information for international buyers as of 2026. Rates, thresholds and rules change and depend on the individual case; it is not legal or tax advice. Before any purchase we put you in touch with the notary, attorney and tax advisor competent for your situation.

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