Thinking about moving to Dublin with a foot in both worlds? We walk through the easy part—immigration with dual U.S.–Irish citizenship—and then open the door to the financial maze most folks miss: how two tax systems collide over your retirement savings. The headline insights are clear and practical: the U.S.–Ireland Double Taxation Agreement provides a framework, but the saving clause keeps U.S. citizens within the IRS net. That’s why the foreign tax credit becomes your day-to-day tool, often letting higher Irish tax erase U.S. liability on the same income while demanding precise annual filings.

We break down how traditional 401k and IRA distributions are taxed in Ireland as foreign pension income, how USC layers on, and how Form 1116 typically neutralizes U.S. tax. We also share a potential bright spot: many experts interpret the treaty to allow qualified Roth IRA withdrawals to remain tax-free in both countries, a powerful planning edge if confirmed for your facts. Social Security gets its own carve out too—taxed in Ireland and generally exempt in the U.S. for Irish residents—simplifying that particular stream.

The real hazard isn’t what you withdraw. It’s what grows inside your accounts. Ireland’s deemed disposal rules for offshore funds can trigger tax on unrealized gains every eight years, even with no sale. If the underlying mutual funds or ETFs in your U.S. plans are treated as offshore funds, that phantom tax bill can blow up decades of planned tax deferral. We outline the exact questions to ask a cross-border tax advisor, why you should get guidance in writing, and how to act before you become an Irish resident: review holdings, identify non-reporting funds, consider restructuring or liquidating problem assets, and prepare a cash and compliance plan that respects both systems.

If you’re weighing a move or already packing boxes, this is your roadmap to preserving compounding, avoiding avoidable tax, and turning dual citizenship from a paperwork perk into a financial advantage. Subscribe, share with a friend planning a move, and leave a review with the one rule you most need clarified—we’ll tackle it in a future deep dive. 

More info at Relocating to Ireland for dual-citizenship couple with U.S. assets (https://https://investingforexpats.com/ie/relocating-to-ireland-for-dual-citizenship-couple).

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Moving, Working, and Investing for Americans Abroad

A simple question—can a UK pension be rolled into a US IRA or 401(k)?—opens a door to some of the most punishing rules in cross‑border retirement planning. We walk through the hard stop that HMRC’s QROPS regime creates, why no US plans qualify, and how an “unauthorized payment” can unleash a 55% UK charge that vaporizes decades of savings. Then we pressure-test the popular third‑country workaround, showing how the 25% overseas transfer charge, US income tax, and foreign trust reporting can turn a detour into a double‑tax minefield.

The conversation shifts from escape routes to smart management: keep the pension in the UK, but invest with the US tax code in mind. That’s where an international SIPP shines. By consolidating old schemes, cutting fees, adding currency flexibility, and—most importantly—letting you hold US‑compliant assets, an international SIPP helps you avoid the IRS’s PFIC regime that punishes many UK-domiciled funds. We dig into the practicalities of building a portfolio inside a UK wrapper that the IRS can live with, so you can protect returns and simplify your US tax life.

Finally, we map out withdrawals under the US–UK treaty. The often‑quoted 25% pension commencement lump sum can be tax‑free in the UK and federally tax‑free in the US, while the remaining drawdowns are generally taxed only where you live. But there’s a twist that catches many savers: states aren’t bound by federal treaties. Depending on your state of residence at the time you take the lump sum, a “tax‑free” benefit may be subject to state income tax. We break down the planning moves that matter—timing, residency, and coordination with your broader retirement picture—so you avoid penalties, sidestep PFICs, and keep more of what you’ve earned.

More information at No, You Can’t transfer a UK Pension into A US 401(k) or IRA. (https://investingforexpats.com/uk-pension-transfer-to-usa)

If this helped clarify your path, follow, share with a friend facing cross‑border pension choices, and leave a quick review so more people can find the show.

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Moving, Working, and Investing for Americans Abroad

Two tax systems. One retirement account. If you’re a U.S. citizen living in Ireland, every withdrawal choice carries outsized consequences—and a few of them can quietly cost six figures. We break down the practical path to keeping more of your money while staying compliant on both sides of the Atlantic.

We start with the core problem: the U.S. taxes based on citizenship while Ireland taxes residents on worldwide income. The treaty helps but the saving clause means the U.S. still wants its slice. That’s where the foreign tax credit comes in. We walk through how to file, why USC matters for the credit, and why paperwork is the price of avoiding double tax. Then we split the planning conversation: traditional accounts are taxable in both countries, so the FTC is essential. Qualified Roth distributions, taken periodically, can be tax-free in both jurisdictions under Ireland’s Section 200—a rare and powerful advantage.

The game changes with lump sums. Since January 2023, Ireland’s Section 200A imposes a tiered tax on lump sums from foreign pensions, overriding the Roth-friendly rule. We map the brackets, show the math on a mid-six-figure withdrawal, and explain why the method of access can matter more than whether it’s Roth or traditional. From there, we dig into non-domiciled status and the remittance basis. If you’re resident but non-domiciled, Ireland only taxes foreign income when remitted—yet “remittance” includes far more than bank transfers. A Dublin ATM withdrawal, paying Irish bills with U.S. funds, or settling a U.S. card used in Ireland can all trigger tax.

To keep control, we outline the clean capital strategy: segregate pre-residency savings from post-move pension income. Avoid mixed funds that cause Irish Revenue to deem remittances as taxable first, trapping your clean capital. Set up two accounts before moving, use clean capital for living costs, and time pension remittances when the tax impact fits your plan. Along the way, we share clear takeaways: file for the FTC, favor qualified Roth periodic draws, avoid lump sums, and protect the remittance basis with strict account hygiene.

If this helped clarify your next steps, follow the show, share this episode with a fellow expat, and leave a rating or review to help others find these strategies.

More information at Taxation of US Retirement Account Distributions for US citizens in Ireland.)

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Moving, Working, and Investing for Americans Abroad

Thinking about trading a U.S. zip code for a German postcode? We break down the smartest routes to make that move real—what’s changed, what still trips people up, and how to land with confidence. From the Schengen 90-day entry window to the infamous Anmeldung loop, we lay out the sequence that actually works so you can avoid costly delays and circular paperwork.

The big news shapes the whole journey: updated EU Blue Card rules with 2025 salary thresholds, plus a crucial opening for IT specialists to qualify without a formal degree if their experience proves the skill. Add in a fast track to permanent residency—21 months with B1 German or 27 months without—and a landmark shift in nationality law allowing dual U.S.–German citizenship with shorter naturalization timelines. If you’ve been on the fence, policy finally caught up with how modern careers and families move.

We also get specific about jobs and credentials. Germany’s skilled worker shortage puts IT, engineering, healthcare, and trades in the spotlight, while regulated roles may still require formal recognition. We explain the first 30 days step-by-step: secure housing, register your address, open a bank account, and set up health insurance—why the order matters and how temporary furnished places can bridge SCHUFA gaps. Then we zoom out to the human side: direct communication, punctuality, real work–life boundaries, and the outsized payoff of learning German through subsidized integration courses.

If you want a practical blueprint—what to do, when to do it, and how the new rules change your odds—you’re in the right place. Subscribe for more deep dives, share this with a friend who’s Germany-curious, and leave a review with your biggest question so we can tackle it next.

More information at Relocating to Germany for United States Citizens.

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Moving, Working, and Investing for Americans Abroad

Wondering if Italy's tax incentives could be your ticket to la dolce vita? Today we unpack the four major tax schemes designed to attract specific types of new residents to Italy in 2024.

The landscape has shifted dramatically. The popular Impatriates regime for skilled workers now offers a 50% tax exemption (60% with children) on income up to €600,000 for five years—but with much stricter qualification requirements than before. We break down the new educational prerequisites and the extended non-residency periods (3-7 years depending on your situation) that create significant hurdles for many potential applicants.

For the wealthy, Italy's High Net Worth Individual scheme delivers predictability through a fixed €200,000 annual payment covering all foreign income, plus exemptions from wealth, inheritance, and reporting requirements. But timing is everything—this rate doubled from €100,000 for anyone establishing residency after August 9, 2024.

Retirees haven't been forgotten. A special 7% flat tax on foreign income awaits those willing to settle in smaller southern communities, while academics receive the most generous benefit of all: a stunning 90% tax exemption on teaching and research income for at least six years.

These carefully targeted incentives reveal Italy's strategic priorities beyond simple tax collection—from addressing regional economic imbalances to reversing brain drain and attracting specific demographic groups. Each scheme comes with precise eligibility requirements and critical deadlines that could mean hundreds of thousands in tax differences.

Ready to explore if these incentives align with your situation? Dive in with us to understand the opportunities, limitations, and strategic thinking behind Italy's approach to attracting global talent and wealth through its tax system.

For more information see  A Guide to Special Regimes for New Residents in Italy.

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Moving, Working, and Investing for Americans Abroad

The nightmare of double taxation haunts countless Americans living abroad. That sinking feeling when tax season arrives—wondering if you'll truly have to pay taxes both in your new home and to the IRS—can overshadow the excitement of your international lifestyle. But there's powerful relief available that many expats don't fully understand or utilize effectively.

This deep dive explores the two most important provisions designed specifically to alleviate this burden: the Foreign Earned Income Exclusion (FEIE) and the Foreign Tax Credit (FTC). While both aim to prevent double taxation, they operate through fundamentally different mechanisms, offering distinct advantages depending on your unique situation.

The FEIE allows qualifying taxpayers to exclude up to $130,000 (for 2025) of foreign earned income from US taxation entirely. We break down the qualification requirements—either establishing bona fide residence abroad or meeting the physical presence test of 330 days outside the US in a 12-month period. Each approach has specific benefits and limitations worth understanding before making your choice.

For those earning above the FEIE threshold or living in higher-tax countries like much of Western Europe, the FTC offers a dollar-for-dollar credit against your US tax liability based on taxes paid to foreign governments. With no income cap and the ability to carry unused credits forward for ten years, it provides significant flexibility for higher earners.

Beyond immediate tax savings, your choice between these provisions has long-lasting implications for retirement planning, investment strategies, and even Social Security benefits. We highlight critical pitfalls to avoid, including how FEIE can affect your ability to contribute to IRAs and the five-year lockout period if you switch from FEIE to FTC.

Whether you're an established expat or considering an international move, mastering these tax provisions is essential for protecting your financial future while enjoying your global lifestyle. Subscribe to our podcast for more expert insights on navigating the complexities of international taxation and wealth management.

For detailed information, consult IRS Publication 54 (Tax Guide for US Citizens and Resident Aliens Abroad) and Publication 514 (Foreign Tax Credit for Individuals).

For easier reading, start with "U.S. Taxes for Americans Working Abroad: FEIE vs. FTC".

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Moving, Working, and Investing for Americans Abroad

Ever wondered if those "simple" financial solutions actually create more problems than they solve? That's exactly what we discovered when examining Transfer on Death (TOD) and Payable on Death (POD) accounts for Americans living abroad.

These accounts seem like perfect solutions - they transfer assets directly to beneficiaries and bypass probate. But cross borders, and suddenly their simplicity unravels dramatically. While technically valid under US state laws, they create a perfect storm of practical challenges, tax complications, and unexpected consequences for expatriates.

We reveal why these accounts frequently trigger estate liquidity crises, leaving executors unable to pay taxes and expenses. We explore how they can accidentally sabotage sophisticated tax planning, potentially costing heirs thousands in avoidable taxes. For beneficiaries with special needs or minors, these accounts can create particularly disastrous outcomes, sometimes even jeopardizing essential government benefits.

The alternative? For most Americans abroad, a revocable living trust provides the flexibility and protection cross-border lives demand. We break down five essential recommendations for creating a robust international estate plan: conducting a global asset inventory, finding dual-qualified advisors who understand both systems, prioritizing trust-based planning, using beneficiary designations strategically if at all, and implementing regular reviews as life circumstances change.

Whether you're already living overseas or considering an international move, this deep dive provides critical insights to protect your assets and loved ones across borders. Take the time now to question whether your estate plan's simplicity truly serves your global situation or if it's hiding costly complications your heirs will eventually face.

More details on Efficacy and Tax Consequences of U.S. TOD and POD Accounts for American Expatriates.

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Moving, Working, and Investing for Americans Abroad

The financial complexities faced by American investors in Ireland represent a perfect storm of conflicting tax systems, hidden pitfalls, and reporting burdens. Caught between US citizenship-based taxation and Irish residency-based rules, many expatriates find themselves navigating a labyrinth of obligations that can significantly impact their investment returns.

Our comprehensive discussion unravels the fundamental tension between these two systems and explores how they interact in real-world scenarios. We break down the key elements of Irish taxation affecting investors, including the progressive income tax structure (20-40%), Dividend Withholding Tax (25%), Capital Gains Tax (33%), and the particularly problematic "deemed disposal" rule. This unique Irish regulation forces investors to pay a 41% tax on fund growth every eight years whether they sell or not—a mechanism that seriously undermines long-term compounding and creates cash flow challenges for those holding Irish or EU-domiciled funds.

On the US side, we examine how citizenship-based taxation follows Americans everywhere, the critical difference between the Foreign Earned Income Exclusion (for employment income) and Foreign Tax Credits (for investment returns), and the notorious PFIC rules that make most non-US investment funds tax-inefficient nightmares for American investors. We also highlight essential reporting requirements like FBAR and FATCA, where non-compliance penalties can be severe.

The podcast provides practical strategies for cross-border investors, from leveraging the US-Ireland tax treaty's reduced withholding rates to selecting US-domiciled ETFs that avoid both PFIC classification and Irish deemed disposal taxes. We consider real estate investments, currency exchange risks, and the importance of proper tax documentation to ensure treaty benefits.

Whether you're planning a move to Ireland, already living there, or simply investing across these borders, this episode equips you with the knowledge to make more informed decisions. The cross-border investment landscape may be challenging, but with the right understanding and professional guidance, US citizens can still build wealth effectively while maintaining compliance with both tax systems.

More information at Financial Planning when Moving to Ireland

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Moving, Working, and Investing for Americans Abroad

Have you ever wondered what happens to everything you've built abroad when you're no longer around? For American expatriates, this question unlocks a labyrinth of complex tax implications that could dramatically affect your legacy.

The United States stands almost alone in how it taxes citizens worldwide, regardless of where they live. This creates what estate planning experts call an "exemption cliff" – while US residents enjoy a generous $14 million estate tax exemption, this can plummet to just $60,000 for Americans living abroad under certain circumstances. This 99.5% reduction represents one of the most shocking tax traps facing global Americans.

Tax treaties between countries might seem like the solution, but they contain surprises of their own. Most include a "savings clause" that preserves the US government's right to tax citizens as if the treaty didn't exist. Rather than eliminating double taxation, treaties typically provide a framework for coordination through foreign tax credits. The type of treaty matters tremendously – older "situs-based" treaties focus on where assets are located, while modern "domicile-based" agreements look at where your life is centered, requiring ongoing "domicile hygiene" to manage how your personal connections are officially viewed.

Common pitfalls abound: US-style trusts may be invalid or problematic overseas, a single will rarely works globally, and getting advice from just one country's experts almost guarantees expensive mistakes. The solution? Assemble a coordinated team of professionals from both the US and your country of residence who understand cross-border complexities.

Beyond the technical details lies a profound question worth reflecting on: Where is your true home, your center of vital interests? Your answer shapes not just your tax situation, but your entire legacy. Take the first step toward protecting what you've built by understanding how deeply your sense of belonging impacts your estate in our interconnected world.

For more information read US Estate and Inheritance Tax for Americans Abroad

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Moving, Working, and Investing for Americans Abroad

Franco-American inheritance planning presents a complex web of conflicting tax systems and legal principles that can significantly impact expatriates' legacies without proper planning.

• French inheritance tax focuses on beneficiaries, with tax rates varying dramatically based on relationship (0% for spouses, up to 60% for unrelated beneficiaries)
• US maintains citizenship-based taxation, claiming worldwide assets regardless of residency
• French forced heirship rules legally reserve portions of estates for children, limiting testamentary freedom
• The 1978 France-US Estate Tax Treaty creates complex rules determining which country has primary taxing rights
• Notaires in France and executors in the US must coordinate to file proper documentation in both countries
• Strategic lifetime gifting can utilize the €100,000 tax-free allowance that renews every 15 years
• Assurance Vie (French life insurance) provides exceptional benefits, operating outside forced heirship rules
• US trusts often create complications in France, potentially triggering punitive tax treatment
• Effective planning requires a "bilingual strategy" addressing both systems holistically
• Professional guidance with Franco-American expertise is essential for navigating this complex landscape

What assumption might you hold about your estate planning, based on US principles, that needs reevaluation given France's fundamentally different approach?

Read French Inheritance tax for U.S. Citizens Resident in France for more information.

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Moving, Working, and Investing for Americans Abroad