1. Should the Italian bank’s general manager hire a commercialista and pay busterella?
2. Should the general manager phone the bank’s American CEO in New York and ask for advice?
3. If you were the bank’s American CEO, would you want to receive the phone call for advice?

The Italian federal corporate tax system has an official, legal tax structure and tax rates just as the U.S. system does. However, all similarity between the two systems ends there. The Italian tax authorities assume that no Italian corporation would ever submit a tax return which shows its true profits but rather would submit a return which understates actual profits by anywhere between 30 percent and 70 percent; their assumption is essentially correct. Therefore, about six months after the annual deadline for filing corporate tax returns, the tax authorities issue to each corporation an “invitation to discuss” its tax return.