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  • Time is running out to become compliant with the Internal Revenue Service (“IRS”) for U.S. citizens (living in the U.S. or Italy) or, alternatively, Italian citizens living in the U.S. (with a “green card” or U.S. tax residency established under the alternative substantial presence test) that have not disclosed all their non-U.S. financial accounts (and related income, if applicable) in their U.S. tax return filings