Events – Irish / U.S. Tax Specialists – Dublin

Pension Issues for People with combinations of US and Irish Citizenship, Tax Residence, Domicile or Green Cards

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No Mutual Pension recognoition

The USA-Ireland Double Taxation Treaty does not provide mutual recognition and reliefs of pension funds. Each state taxes pensions from the other in a punitive manner. This puts people who split their careers between Ireland and the USA at a significant disadvantage.

Automatic Pensions Enrolment

Ireland is introducing automatic pension enrolment in September 2025 along the Australian model. American expats will be into mandatory reporting.

Irish Pension reporting to IRS

Irish held pensions must be reported to the IRS if owned by a US Person. Financial institution provide the IRS with data to check against.

The USA-Ireland Double Taxation Treaty does not provide mutual recognition and reliefs of pension funds.

Irish Pension funds held by US taxpayers and/or citizens are regarded as overseas financial investments by the US IRS and must be declared annually on penalty of substantial fines ($10k+ per year)

Irish residents, including former Green Card holders and individuals entitled to US citizenship through American parents, may not be aware that they are required to report any Irish financial accounts to the IRS. This includes accounts such as pension plans, insurance policies, bank accounts, and services like PayPal and Revolut.

Compulsory Pension Enrolment is being rolled out in Ireland in September 2025

US Pension funds such as a Roth 401(k) or IRAs are regarded by the Irish Revenue as regular investment accounts which do not qualify for tax free treatment and are subject to Irish income taxes.

In short this means that many people resident in Ireland with US links, either have today, or after September 2025 will have, very significant tax exposure on their pension savings.

We are part of a partnership currently working on developing pension products that can minimise tax exposure for those impacted by the issues above.

See below if you would like to receive further info when these products launch, to attend an information event on November 28th, or to complete our short 4 question survey (1 minute) to collect facts to lobby government for equal tax treatment for people who have split their working-age or pension lives between the US and Ireland.