It is increasingly common for individuals who are Irish tax resident and Irish domiciled to hold US-situs assets, whether through direct shareholdings in US listed companies, US-domiciled exchange traded funds (ETFs), or interests in US entities such as limited liability companies (LLCs). Although the US tax exposure for US citizens is generally well understood, a less recognised issue arises where Irish residents who are not US citizens hold US assets. In such cases US estate tax or US gift tax can arise, often at relatively modest asset values and without any corresponding Irish tax charge.
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