US Citizen Retiring in Ireland

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LIGuy82
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US Citizen Retiring in Ireland

Post by LIGuy82 » Wed Jun 12, 2019 2:04 pm

I have 13 years until retirement and would rather do everything right from the start. My spouse is a dual Irish-US national and I am American. We plan to retire, for at least part of the year, in Ireland. In retirement I will receive a government pension, social security, rental income, and whatever I withdraw from retirement accounts. Ireland’s taxes are much higher than in the US from what I can see and I thought that if I put some planning into it this far in advance, I may be able to minimize our tax burden in retirement.

I am just not sure where to start looking into this. My accountant offered to look into it, but given their lack of experience in this very narrow field, I was curious if bogleheads out there could either offer advice or refer an expert. Thanks in advance for your responses.

magicrat
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Re: US Citizen Retiring in Ireland

Post by magicrat » Wed Jun 12, 2019 2:52 pm

If it were me, I'd consult a tax attorney with relevant experience.

Topic Author
LIGuy82
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Re: US Citizen Retiring in Ireland

Post by LIGuy82 » Wed Jun 12, 2019 2:54 pm

magicrat wrote:
Wed Jun 12, 2019 2:52 pm
If it were me, I'd consult a tax attorney with relevant experience.
Thanks - that’s why I’m here looking for a recommendation. Tried googling but everyone’s very happy to perform a service for a fee but can’t explain why they are suited to do it. Thought someone here might have someone they can recommend.

magicrat
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Re: US Citizen Retiring in Ireland

Post by magicrat » Wed Jun 12, 2019 2:58 pm

LIGuy82 wrote:
Wed Jun 12, 2019 2:54 pm
magicrat wrote:
Wed Jun 12, 2019 2:52 pm
If it were me, I'd consult a tax attorney with relevant experience.
Thanks - that’s why I’m here looking for a recommendation. Tried googling but everyone’s very happy to perform a service for a fee but can’t explain why they are suited to do it. Thought someone here might have someone they can recommend.
https://www.prplawllc.com/services

finfire
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Re: US Citizen Retiring in Ireland

Post by finfire » Wed Jun 12, 2019 3:01 pm

There is a US Ireland Tax treaty: https://www.irs.gov/pub/irs-trty/ireland.pdf

Not sure if it is any help.

Good luck. A great country to live in, with easy access to Europe.

DJN
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Re: US Citizen Retiring in Ireland

Post by DJN » Wed Jun 12, 2019 3:01 pm

Hi,
there are a few relevant links to the Irish tax authorities in the Wiki sections on Ireland: https://www.bogleheads.org/wiki/Investing_from_Ireland
The subject of taxation of US citizens in Ireland is complex. The possibility for a non domiciled individual may be of interest and deserves some research. There is a longstanding tax treaty between the US and Ireland and you should read this. You will need to navigate the US laws on taxation and I am not any use to you on that one, read some of Ted Swippet's posts. As a non domiciled person you could be able to avail of the remittance basis for your taxation.
DJN
It's a constant source of amazement to me, how little I know and how much there is to find out.

bsteiner
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Re: US Citizen Retiring in Ireland

Post by bsteiner » Wed Jun 12, 2019 5:27 pm

The U.S. also has an estate tax treaty with Ireland.

fru-gal
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Re: US Citizen Retiring in Ireland

Post by fru-gal » Wed Jun 12, 2019 6:00 pm

My vague impression is that high tax "European" countries are high tax because they provide things like "free" healthcare and many other substantial social services, including to the elderly. I don't know if Ireland is in this category, but this is something to take into account.

Skiandswim
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Re: US Citizen Retiring in Ireland

Post by Skiandswim » Thu Jun 13, 2019 3:20 am

Deloitte Ireland provides a comprehensive tax guide. https://www2.deloitte.com/content/dam/D ... -guide.pdf

Tax and medical systems are one consideration for an international move (or retirement). I find that people need to spend more time planning for and adapting to cultural changes; building friendships, social environment, hobbies, weather (in case of Ireland), distance from US family / friends, bureaucracy differences, etc.

AlohaJoe
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Re: US Citizen Retiring in Ireland

Post by AlohaJoe » Thu Jun 13, 2019 3:55 am

Unless you are going to be spending six months a year in Ireland....it doesn't matter. Stay under 183 days and you don't owe any taxes to Ireland. That's a fairly consistent rule for most countries.

DJN
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Re: US Citizen Retiring in Ireland

Post by DJN » Thu Jun 13, 2019 4:04 am

Hi,
a few more updates:
here is the location in Wiki for the tax position for a US person investing from outside the US: https://www.bogleheads.org/wiki/Taxatio ... ing_abroad This should be a good starting point for the tax position for you.
- while the tax free estate tax position for US citizens is large, the same cannot be said of non US citizens in possession of US assets. ($60,000 upper limit applies and above that estate tax at 40% is applicable on US situs assets).
- if you invest as an Irish citizen in etfs you will be obliged to invest in UCITS and will not normally have access to US funds.
- the tax regime on UCITS for Irish taxpayers is 40% on all gains and is applied every 8 years either on a sale or on a deemed disposal and capital losses cannot be offset.
- if you have a portfolio of shares this will be taxed at your marginal rate + PRSI + USC and capital losses can be offset.
DJN
Last edited by DJN on Fri Jun 14, 2019 6:47 am, edited 1 time in total.
It's a constant source of amazement to me, how little I know and how much there is to find out.

mick-madden
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Re: US Citizen Retiring in Ireland

Post by mick-madden » Thu Jun 13, 2019 5:58 am

As mentioned above, investing in ETFs (or anything) in Ireland is much less tax/expense efficient than the US.

You’re best bet, I think, would be to speak to an Irish Accountant that has experience with drawing income from overseas investment accounts / pensions. There’s dual tax agreement nuances etc that you can read into, but the Irish accountant will know and be able to tell you pretty quickly. You might even get a cheap 15 minute conversation with one.

As for what you need to do right now - and for the next 13 years - stay the course, and continue saving / maximizing your tax deferred accounts.
No fear, No envy, No meanness

Valuethinker
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Re: US Citizen Retiring in Ireland

Post by Valuethinker » Thu Jun 13, 2019 10:21 am

fru-gal wrote:
Wed Jun 12, 2019 6:00 pm
My vague impression is that high tax "European" countries are high tax because they provide things like "free" healthcare and many other substantial social services, including to the elderly. I don't know if Ireland is in this category, but this is something to take into account.
Basically yes. The Global Financial Crisis damaged Ireland very badly and debt to GDP is high - basically the government absorbed the debt of the banks that went bust. So taxes are high in part to repay that. The economy is now, however, growing well again - Brexit could cause major disruption (we are their largest export destination) but conversely it will create opportunities (financial and professional services companies relocating to Dublin from London).

Irish healthcare is free at the point of dispense, AFAIK, and is financed out of general taxation. There are no uninsured either voluntarily or not - it's a universal right and a universal obligation (to pay taxes).

Now. What happens to a retiree who does not have years in the Irish social security system I do not know. Many countries restrict immigration by retirees for just this reason, or require them to buy private insurance (France is in the latter camp, I believe). It turns out in some countries your non-citizen spouse does not have automatic right to remain even though you are a natural born citizen (this is true of the UK for example).

It may be as a foreigner resident in Ireland, non working, you are required to buy private insurance or to make some sort of contribution - that's worth checking.

I couldn't tell you about the Irish social care system (nursing home care). I can tell you the England + Wales one is in crisis.

Because of the historic ties between the 2 countries there may be special treaty arrangements re Irish & American citizens in each other's countries. Generally Ireland's joining the EU won't have eliminated those.
Last edited by Valuethinker on Thu Jun 13, 2019 10:25 am, edited 2 times in total.

Valuethinker
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Re: US Citizen Retiring in Ireland

Post by Valuethinker » Thu Jun 13, 2019 10:22 am

LIGuy82 wrote:
Wed Jun 12, 2019 2:04 pm
I have 13 years until retirement and would rather do everything right from the start. My spouse is a dual Irish-US national and I am American. We plan to retire, for at least part of the year, in Ireland. In retirement I will receive a government pension, social security, rental income, and whatever I withdraw from retirement accounts. Ireland’s taxes are much higher than in the US from what I can see and I thought that if I put some planning into it this far in advance, I may be able to minimize our tax burden in retirement.

I am just not sure where to start looking into this. My accountant offered to look into it, but given their lack of experience in this very narrow field, I was curious if bogleheads out there could either offer advice or refer an expert. Thanks in advance for your responses.
Just from an investing point of view US tax rules (PFIC) mean you are best advised to continue investing via the mechanism of US domiciled funds.

Non US domiciled funds are a tax nightmare for an American citizen, as I understand it.

Topic Author
LIGuy82
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Re: US Citizen Retiring in Ireland

Post by LIGuy82 » Thu Jun 13, 2019 11:00 am

Valuethinker wrote:
Thu Jun 13, 2019 10:21 am
fru-gal wrote:
Wed Jun 12, 2019 6:00 pm
My vague impression is that high tax "European" countries are high tax because they provide things like "free" healthcare and many other substantial social services, including to the elderly. I don't know if Ireland is in this category, but this is something to take into account.
Basically yes. The Global Financial Crisis damaged Ireland very badly and debt to GDP is high - basically the government absorbed the debt of the banks that went bust. So taxes are high in part to repay that. The economy is now, however, growing well again - Brexit could cause major disruption (we are their largest export destination) but conversely it will create opportunities (financial and professional services companies relocating to Dublin from London).

Irish healthcare is free at the point of dispense, AFAIK, and is financed out of general taxation. There are no uninsured either voluntarily or not - it's a universal right and a universal obligation (to pay taxes).

Now. What happens to a retiree who does not have years in the Irish social security system I do not know. Many countries restrict immigration by retirees for just this reason, or require them to buy private insurance (France is in the latter camp, I believe). It turns out in some countries your non-citizen spouse does not have automatic right to remain even though you are a natural born citizen (this is true of the UK for example).

It may be as a foreigner resident in Ireland, non working, you are required to buy private insurance or to make some sort of contribution - that's worth checking.

I couldn't tell you about the Irish social care system (nursing home care). I can tell you the England + Wales one is in crisis.

Because of the historic ties between the 2 countries there may be special treaty arrangements re Irish & American citizens in each other's countries. Generally Ireland's joining the EU won't have eliminated those.
Thanks - these are all good points. Along with pension and early social security, Uncle Sam will continue paying for my healthcare and I just need to pay my end of the premium. I could eventually get citizenship, but want to figure out what that would get me and what it would cost me. Already reached out to a professional and we’ll see what they say. I’m sure there will end up being a plan where we live in the US for six months and a day per year or something like that.

I appreciate that you put “free” in quotes when talking about healthcare. Yeah, everyone gets it...and waits in the same line. Those with means and many, many middle class people buy private insurance on top of what they pay in taxes and investments are taxes at staggering rates. We’re planning to move there one day to be closer to family, but I want to do everything I can in advance to avoid getting raided.

clip651
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Re: US Citizen Retiring in Ireland

Post by clip651 » Thu Jun 13, 2019 12:04 pm

Just something to think about regarding long term residency ...

It's fine to plan to be in the US for the required number of days to keep residency here, and spend the rest of the time elsewhere (or vice versa with the other country as primary residency). But this may become complicated if/when one of you becomes ill or incapacitated someday. It's not simple to hop on a plane on a particular schedule if you are managing a chronic medical condition, or fighting cancer, or whatever else may come up for short or long term medical problems. Not fun to think about, but just something to factor into long term planning. Anyone living well into old age is likely to hit a point where they really need to just stay in one place, and not plan to travel back and forth, even if it's just a matter of bad arthritis making travel much more difficult with time. I'm sure there are ways to plan for this. Just throwing it out for consideration.

Ireland sounds like a lovely place to retire!
best wishes,
cj

international001
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Re: US Citizen Retiring in Ireland

Post by international001 » Thu Jun 13, 2019 2:57 pm

Valuethinker wrote:
Thu Jun 13, 2019 10:22 am

Just from an investing point of view US tax rules (PFIC) mean you are best advised to continue investing via the mechanism of US domiciled funds.

Non US domiciled funds are a tax nightmare for an American citizen, as I understand it.
I thought it was not allowed anways, by FATCA

international001
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Re: US Citizen Retiring in Ireland

Post by international001 » Thu Jun 13, 2019 3:04 pm

magicrat wrote:
Wed Jun 12, 2019 2:58 pm

https://www.prplawllc.com/services
It seems aimed to help people who move into US. Would they advice anybody moving out of US to any EU country?
Do you know what kind of $$ they charge for their services?

magicrat
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Re: US Citizen Retiring in Ireland

Post by magicrat » Thu Jun 13, 2019 3:10 pm

international001 wrote:
Thu Jun 13, 2019 3:04 pm
magicrat wrote:
Wed Jun 12, 2019 2:58 pm

https://www.prplawllc.com/services
It seems aimed to help people who move into US. Would they advice anybody moving out of US to any EU country?
Do you know what kind of $$ they charge for their services?
Not sure you’ll have to ask. I work with them in other topics. They’re high end lawyers and their fees reflect that.

magicrat
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Re: US Citizen Retiring in Ireland

Post by magicrat » Thu Jun 13, 2019 3:10 pm

international001 wrote:
Thu Jun 13, 2019 3:04 pm
magicrat wrote:
Wed Jun 12, 2019 2:58 pm

https://www.prplawllc.com/services
It seems aimed to help people who move into US. Would they advice anybody moving out of US to any EU country?
Do you know what kind of $$ they charge for their services?
Not sure you’ll have to ask. I work with them in other topics. They’re high end lawyers and their fees reflect that.

4nwestsaylng
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Re: US Citizen Retiring in Ireland

Post by 4nwestsaylng » Thu Jun 13, 2019 9:50 pm

clip651 wrote:
Thu Jun 13, 2019 12:04 pm
Just something to think about regarding long term residency ...

It's fine to plan to be in the US for the required number of days to keep residency here, and spend the rest of the time elsewhere (or vice versa with the other country as primary residency). But this may become complicated if/when one of you becomes ill or incapacitated someday. It's not simple to hop on a plane on a particular schedule if you are managing a chronic medical condition, or fighting cancer, or whatever else may come up for short or long term medical problems. Not fun to think about, but just something to factor into long term planning. Anyone living well into old age is likely to hit a point where they really need to just stay in one place, and not plan to travel back and forth, even if it's just a matter of bad arthritis making travel much more difficult with time. I'm sure there are ways to plan for this. Just throwing it out for consideration.

Ireland sounds like a lovely place to retire!
best wishes,
cj
This is the most important point in this thread. Regardless of family ties to another country, as you age you will likely need more health care, so you want to know where your real base is, either it is the U.S. or the other country. You could have an emergency of course and require care in Ireland, but my experience with Irish ex-pat doctors in Canada (yes, they left Ireland for Canada, something to think about!) is that they are very well trained.

Regardless, you might get a number of good years first with a less than six months in Ireland arrangement, and from that point maybe make visits for a month or so a couple of times a year, between rainy weather (which is why they have those cosy pubs!).

I think Ireland has a great future because of its people and work ethic, and will likely do very well with Brexit, probably actually better,contrary to popular belief.

Tribonian
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Re: US Citizen Retiring in Ireland

Post by Tribonian » Thu Jun 13, 2019 11:14 pm

I have not investigated personally, but it is my understanding that Ireland requires a number of years of legal residency for non-EU citizens before health care benefits accrue. When relatives looked into it years ago, the requirement was long- something like 10 years.

Ireland also used to have (and may still) a scheme to not tax the revenue of professional artists who resided there.

Big Mig
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Re: US Citizen Retiring in Ireland

Post by Big Mig » Fri Jun 14, 2019 12:02 am

Tribonian wrote:
Thu Jun 13, 2019 11:14 pm
I have not investigated personally, but it is my understanding that Ireland requires a number of years of legal residency for non-EU citizens before health care benefits accrue. When relatives looked into it years ago, the requirement was long- something like 10 years.
HSE’s eligibility requirements here: https://www.hse.ie/eng/services/find-a- ... ility.html Basically you have to intend to live in Ireland for at least a year to be eligible to use health services.

TedSwippet
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Re: US Citizen Retiring in Ireland

Post by TedSwippet » Fri Jun 14, 2019 3:06 am

bsteiner wrote:
Wed Jun 12, 2019 5:27 pm
The U.S. also has an estate tax treaty with Ireland.
It does, but it is elderly and for non-US citizens it's actually a poor one, since it appears not to protect US assets above a stingy $60k. This is not a problem for US citizens, though; on the US side they still get the full $11mm or whatever.
international001 wrote:
Thu Jun 13, 2019 2:57 pm
Valuethinker wrote:
Thu Jun 13, 2019 10:22 am
Just from an investing point of view US tax rules (PFIC) mean you are best advised to continue investing via the mechanism of US domiciled funds.
Non US domiciled funds are a tax nightmare for an American citizen, as I understand it.
I thought it was not allowed anways, by FATCA
I think you are confusing FATCA with PRIIPs.

Non-US domiciled funds are indeed a tax nightmare for US citizens. PRIIPs will make it difficult or impossible for a US citizen living in Ireland to access US domiciled non-PFIC funds or ETFs through a local broker, but they should still be okay if they retain a US based broker. Unfortunately, several US based brokers now refuse accounts for non-US residents, so care is needed here.

international001
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Re: US Citizen Retiring in Ireland

Post by international001 » Fri Jun 14, 2019 6:30 pm

TedSwippet wrote:
Fri Jun 14, 2019 3:06 am
It does, but it is elderly and for non-US citizens it's actually a poor one, since it appears not to protect US assets above a stingy $60k. This is not a problem for US citizens, though; on the US side they still get the full $11mm or whatever.
What happens if they are US citizens and they leave it to another US citizen, all residing in an EU country. Will the EU country get its share?
TedSwippet wrote:
Fri Jun 14, 2019 3:06 am
Non-US domiciled funds are indeed a tax nightmare for US citizens. PRIIPs will make it difficult or impossible for a US citizen living in Ireland to access US domiciled non-PFIC funds or ETFs through a local broker, but they should still be okay if they retain a US based broker. Unfortunately, several US based brokers now refuse accounts for non-US residents, so care is needed here.
If a US person (US citizen) tries to invest on a EU fund, EU broker will not allow it because it has to comply with US regulations and it's not worth to worry. I had those problems before 2018. I thought that was FATCA

TedSwippet
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Re: US Citizen Retiring in Ireland

Post by TedSwippet » Sat Jun 15, 2019 3:20 am

international001 wrote:
Fri Jun 14, 2019 6:30 pm
TedSwippet wrote:
Fri Jun 14, 2019 3:06 am
It does, but it is elderly and for non-US citizens it's actually a poor one, since it appears not to protect US assets above a stingy $60k. This is not a problem for US citizens, though; on the US side they still get the full $11mm or whatever.
What happens if they are US citizens and they leave it to another US citizen, all residing in an EU country. Will the EU country get its share?
If they are domiciled in that EU country (however "domicile" happens to be defined), then presumably yes.
international001 wrote:
Fri Jun 14, 2019 6:30 pm
TedSwippet wrote:
Fri Jun 14, 2019 3:06 am
Non-US domiciled funds are indeed a tax nightmare for US citizens. PRIIPs will make it difficult or impossible for a US citizen living in Ireland to access US domiciled non-PFIC funds or ETFs through a local broker, but they should still be okay if they retain a US based broker. Unfortunately, several US based brokers now refuse accounts for non-US residents, so care is needed here.
If a US person (US citizen) tries to invest on a EU fund, EU broker will not allow it because it has to comply with US regulations and it's not worth to worry. I had those problems before 2018. I thought that was FATCA
That is probably Regulation S. For a long time now, EU based mutual funds have included a restriction on purchase by 'US persons'. In the case of Regulation S though, the definition of 'US person' it uses is not the same as the normal definition for US tax purposes. Unlike the whole US tax code, Regulation S does not apply to US citizens living outside the US.

And yes, this is all about as unclear as it is possible to get.

SrGrumpy
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Re: US Citizen Retiring in Ireland

Post by SrGrumpy » Sat Jun 15, 2019 11:22 am

Thirteen years is a really, really long time. Tax rules and your own plans won't change in that time?! I would just focus on getting Irish citizenship now.

Big Mig
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Re: US Citizen Retiring in Ireland

Post by Big Mig » Sat Jun 15, 2019 2:13 pm

SrGrumpy wrote:
Sat Jun 15, 2019 11:22 am
Thirteen years is a really, really long time. Tax rules and your own plans won't change in that time?! I would just focus on getting Irish citizenship now.
The OP would need to be resident in Ireland before successfully applying for Irish citizenship (eligibility requirements here: http://www.inis.gov.ie/en/inis/pages/wp16000022). Even if it was possible to become a citizen without being resident first: the OP is apparently a federal government employee, and some federal positions require clearances, and anyone who has or might be interested in such a position would want to give a lot of thought to the possible effects of becoming a dual citizen.

Big Mig
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Re: US Citizen Retiring in Ireland

Post by Big Mig » Sat Jun 15, 2019 2:22 pm

AlohaJoe wrote:
Thu Jun 13, 2019 3:55 am
Unless you are going to be spending six months a year in Ireland....it doesn't matter. Stay under 183 days and you don't owe any taxes to Ireland. That's a fairly consistent rule for most countries.
This isn’t strictly true for Ireland—rather, it’s true for 1 year, but you don’t get another 182 days in the following year. You’re considered a tax resident of Ireland if you spend 183 days or more in one year, or if you spend a total of 280 days or more in Ireland over two consecutive years. https://www.citizensinformation.ie/en/m ... eland.html

michaeljc70
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Re: US Citizen Retiring in Ireland

Post by michaeljc70 » Sat Jun 15, 2019 3:12 pm

fru-gal wrote:
Wed Jun 12, 2019 6:00 pm
My vague impression is that high tax "European" countries are high tax because they provide things like "free" healthcare and many other substantial social services, including to the elderly. I don't know if Ireland is in this category, but this is something to take into account.
Yes, but if they move there full time any money paid into Medicare was for nothing (I know they had no choice). They've paid Medicare taxes their whole life for retiree healthcare and now will be paying taxes for retiree healthcare (if not income, at least VAT).

international001
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Re: US Citizen Retiring in Ireland

Post by international001 » Sun Jun 16, 2019 3:58 pm

TedSwippet wrote:
Sat Jun 15, 2019 3:20 am
If they are domiciled in that EU country (however "domicile" happens to be defined), then presumably yes.
I was thinking more about domiciled in US, hold by US broker
TedSwippet wrote:
Sat Jun 15, 2019 3:20 am

That is probably Regulation S. For a long time now, EU based mutual funds have included a restriction on purchase by 'US persons'. In the case of Regulation S though, the definition of 'US person' it uses is not the same as the normal definition for US tax purposes. Unlike the whole US tax code, Regulation S does not apply to US citizens living outside the US.
Thanks (again!) for all your knowledge. I thought it was FATCA. I had problems when I got the fund in EU in 2009 (I read.. not available for US residents after I had bought it, the local broker had been clueless). So what are the additional restrictions that FATCA added?

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