Moving from the US to Ireland

Immigration

US citizens need an Irish work permit (Critical Skills Employment Permit is the common one for tech/professional roles). Spouse permits are reasonably accessible. After 5 years on a Stamp 4, you can apply for citizenship. Multi-year process — start the visa conversation before signing the offer letter.

The US still taxes you. Forever.

The US is one of two countries (with Eritrea) that tax citizens on worldwide income regardless of residence. Moving to Ireland doesn't end your US filing obligation:

• Form 1040: still due every April. Report worldwide income.
• FEIE (Foreign Earned Income Exclusion): ~$130k of foreign earned income excludable, if you meet bona-fide residence or physical-presence tests.
• FTC (Foreign Tax Credit): dollar-for-dollar credit for Irish income tax paid. Often more useful than FEIE for high earners (Irish tax ≥ US tax on the same income).
• FBAR (FinCEN 114): required if total foreign accounts ever exceeded $10,000 in the year. Includes pension accounts, sometimes brokerage. Penalty for missing it is brutal.
• FATCA Form 8938: thresholds higher than FBAR; usually filed with 1040.

Becoming an Irish tax resident

Irish residency: 183 days in the calendar year, or 280 over two (with at least 30 each). Once you're tax-resident, Ireland gets primary taxing rights on most categories of income, with the US-Ireland Double Tax Agreement allocating between the two countries.

Source: Revenue.ie — Tax residence.

Emergency tax — the first-month gotcha

Without a PPS and Revenue RPN, your first paycheque can lose 50%+ to emergency PAYE. On a $150k-equivalent salary that's tens of thousands withheld unnecessarily.

• Apply for PPS as soon as possible after arrival — needs Irish address proof
• Once PPS issued, register your employment in Revenue myAccount → Revenue issues RPN to your employer → emergency tax stops
• Refunds from over-withholding reconcile automatically once the RPN lands

Run yours through the Emergency Tax estimator to see what's at stake.

401(k)s and Roth IRAs

What happens to retirement accounts when you leave the US:

• Traditional 401(k)/IRA: keep open with your existing broker. The DTA recognises the wrapper — Ireland doesn't tax the growth, only the eventual distributions, taxed as PAYE income. Don't roll it into anything Irish.
• Roth IRA: trickier. The DTA's pension article preserves the tax-free distribution treatment if the account is recognised as a pension by both jurisdictions. Most advisors say Roth IRAs are recognised as a pension under Article 18(1)(b). Get this confirmed in writing for your specific situation.
• RMDs at 73 still apply on the US side once you hit the age — Ireland generally taxes them as PAYE income, with the US tax credited.
• Don't take an early withdrawal to fund the move. The 10% US penalty plus Irish income tax + USC + PRSI on top is typically 50–60% combined.

RSUs and ESPP — different rules now

For US tech employees moving to Ireland, this is often the biggest surprise:

• RSU vests are now Irish PAYE+USC+PRSI at marginal rate (~52%) instead of US W-2 income. Your employer's payroll withholds since 1 Jan 2024. The US still wants to know about the income too — credit for Irish tax avoids double tax.
• ESPP discount: Irish notional pay, withheld via payroll. The 15% bargain element gets taxed at your marginal Irish rate. The salary calculator's benefits panel handles this maths.
• Selling vested shares: Irish CGT (33% with €1,270 exemption) and US capital gains. DTA allocates the rights; credit prevents double tax. Tracking cost basis across both systems is a record-keeping nightmare.

Try the salary calculator with your actual stock award and ESPP %. The RSU guide covers the post-vest sale path.

The PFIC trap — Irish ETFs are radioactive for US persons

Practical moves for US-person investors:

• Hold US-domiciled funds (VTI, VXUS, etc.) in your existing US brokerage. Most Irish brokers won't sell them due to EU PRIIPs KID rules, but your US accounts can.
• Individual stocks (Berkshire, etc.) — clean CGT/US-cap-gains treatment, no PFIC.
• Investment trusts (UK-listed, closed-ended) — QEF election sometimes possible to avoid PFIC penalty regime.
• Pensions (PRSA, occupational): inside the wrapper, neither regime applies. Pension is the cleanest tax-efficient vehicle for a US person in Ireland.

Healthcare

You'll pay out-of-pocket or via private insurance, similar to US experience but cheaper:

• GP visits ~€60–€75
• Private health insurance (VHI / Laya / Irish Life Health): family policy €1,500–€3,000/yr — vs typical US employer premium share
• Public hospital: free with referral, but waiting lists are real for non-urgent care
• HSA/FSA balances stranded in the US — no Irish equivalent

Banking and US-aware accounts

• Most Irish banks will open accounts for US persons but limit investment products due to FATCA reporting overhead.
• Avoid investing through Irish brokerages — most will eventually report you under FATCA, and PFIC rules apply to anything fund-like.
• Keep US brokerage accounts open. Schwab International, Interactive Brokers, and Fidelity all support non-resident US persons.
• Revolut and N26 work but carry FATCA reporting too.

Six-week financial checklist

1. Apply for PPS number (MyWelfare.ie). Bring US passport, proof of address, signed offer letter.
2. Open an Irish bank account or use Revolut/N26.
3. Register employment in Revenue myAccount → triggers RPN.
4. Notify your US brokerage of new address (some restrict trading by non-resident; understand limits before moving).
5. Engage a US-Ireland cross-border tax accountant. Annual cost ~€1,500–€3,000; saves multiples of that and a lot of sleep.
6. File final US Form 1040 covering the partial-year US tax residency. Form 2555/1116 for FEIE/FTC.
7. Calendar the FBAR deadline (15 April with auto extension to 15 October).

Next

• Full newcomer roadmap — first 6 weeks step-by-step
• Emergency tax estimator — what you lose without an RPN
• Salary calculator — RSU + ESPP support built-in
• RSUs in Ireland
• Why ETFs are different here