Dear AtalantaTaxExpert,

First of all, thank you so much for your kind and prompt answer. May God bless all the people like you who help others.

Please let me go further on the subject.
1. From what I understood reading the latest (in force since 2009) US-Italy treaty the taxes should be paid here in Italy and not in the States. Am I missing a point ?
2. What if Carlo sends the money directly to a private U.S. borrower and not to a financial company, then the borrower is not obbligated or entiteled to withhold any taxes?
Thanks again for your attention.

1) Taxes are probably due to Italy as well as the United States, and that is why Carlo can claim a credit on his Italian tax return for the taxes paid to the U.S.

2) It does not matter WHO the interest payer is, be it a financial company or a private U.S. citizen. The interest is STILL taxable income, subject to the 15% tax, and the private borrower would also be obligated to withhold 30% (15% if Form W-8BEN is submitted claiming the treaty amount) from the interest earned and that money sent to the IRS.