US Expat Taxes in Ireland

Who Has to File: Your US Obligations from Ireland

If you are a US citizen or green card holder living in Ireland, you file a US return for every year your gross income crosses the filing threshold. For 2026 that is $16,100 if single, $32,200 if married filing jointly, $400 of net self-employment income, or $5 if you are married to an Irish citizen and file separately. Gross income is counted before the Foreign Earned Income Exclusion, so a Dublin salary always crosses the line, and so does a modest pension or rental profit.

The Form 1040 is only the start. Most Americans in Ireland also owe some of the following:

• FinCEN Form 114 (FBAR) if all your non-US accounts together exceeded $10,000 at any point in the year. AIB, Bank of Ireland, PTSB, Revolut, credit union and An Post accounts all count, and so do PRSAs, occupational pension funds, ARFs and investment accounts with Davy, Degiro or Trade Republic.
• Form 8938 if your foreign financial assets exceed $200,000 at year end or $300,000 at any time. For joint filers living abroad the limits are $400,000 and $600,000.
• Form 2555 or Form 1116, depending on whether you exclude earned income or credit Irish tax against US tax.
• Form 8621 for each Irish or EU-domiciled ETF, UCITS fund or unit-linked policy you hold outside a pension.
• Form 8833 whenever you rely on the US-Ireland treaty, for example on US Social Security or pension sourcing.
• Form 5471 if you own 10% or more of an Irish limited company, and Form 3520 for Irish trusts and some employee share trusts.

Ireland has had a Model 1 FATCA agreement with the US since 2012. Irish banks send your account details to Revenue, which forwards them to the IRS, so the question is never whether the IRS knows about your Irish accounts but whether your return matches what it already holds.

Check your last US state too. If you left California, Virginia, New Mexico or South Carolina with a driver's licence, a house or a voter registration still active, that state may still consider you a resident. Cutting state ties before you fly is cheaper than any treaty argument later.

How Irish Income Tax, USC and PRSI Work in 2026

Ireland charges three separate levies on employment income, and you need all three to work out your Foreign Tax Credit. Budget 2026, delivered on October 7, 2025, left income tax rates and credits unchanged and made one small USC change.

Income tax has two rates. For 2026 a single person pays 20% on the first 44,000 euro and 40% on everything above it. A married couple with one income has a 53,000 euro standard rate band, and a two-income couple can reach 88,000 euro between them. Tax credits then come straight off the bill: a 2,000 euro personal credit for everyone and a 2,000 euro employee (PAYE) credit for employees, or a 2,000 euro earned income credit for the self-employed. Those two credits mean a single employee pays no income tax on roughly the first 20,000 euro.

USC (Universal Social Charge) is charged on gross income with no credits. The 2026 bands are:

• 0.5% on the first 12,012 euro
• 2% on the next 16,688 euro, up to 28,700 euro (the ceiling rose from 27,382 euro in Budget 2026)
• 3% on the next 41,344 euro, up to 70,044 euro
• 8% on everything above 70,044 euro, and 11% on self-employment income above 100,000 euro

PRSI (Pay Related Social Insurance) for Class A employees is 4.2% of all earnings from January 1 to September 30, 2026, rising to 4.35% from October 1, 2026 under the multi-year roadmap that funds the State Pension. There is no ceiling. Employers pay 11.25% on top. Income tax and USC are creditable on Form 1116. PRSI is a social security contribution and is not.

The Irish tax year is the calendar year. That is a real advantage over the UK's April-to-April year: your Irish Employment Detail Summary and your Form W-2 equivalent cover the same twelve months, so no pro-rating is needed on Form 1116.

If your only income is a salary, PAYE withholds everything and you file nothing unless you want to claim credits such as the 1,000 euro rent credit through myAccount. You become a chargeable person and must file a Form 11 through ROS (Revenue Online Service) if you have self-employment income, rental income, foreign income above small limits, or ETF gains. PAYE workers with under 5,000 euro of net non-PAYE income can use the shorter Form 12 instead. Form 11 filers also pay preliminary tax for the current year at the same time, set at 90% of the current-year liability or 100% of the prior year.

Irish Tax Residence: 183 Days, 280 Days, Ordinary Residence and Domicile

Ireland decides residence with day counts, and a day counts if you are present at any time during it. You are Irish tax resident for a calendar year if you spend 183 days or more in Ireland during that year, or 280 days or more across that year and the previous one combined, with at least 30 days in each. The two-year test catches people who arrive in July on a corporate transfer and think they have a year of grace. You can also elect to be treated as resident in your arrival year if you intend to be resident the following year, which is sometimes useful to unlock full credits.

Two further concepts sit above residence:

• Ordinary residence begins once you have been resident for three consecutive tax years and continues for three full years after you leave. While ordinarily resident but non-resident, Ireland still taxes your worldwide income except foreign employment income for duties performed entirely abroad, income from a trade carried on abroad, and other foreign income under 3,810 euro.
• Domicile is a common-law idea of your permanent home. Almost every American in Ireland keeps a US domicile of origin unless they have decided to stay in Ireland for good. Non-domiciled status is what opens the remittance basis described in the next section.

Ireland has no formal split-year rule for investment income, but employment income is split in the year of arrival and departure: only salary for Irish duties after you arrive, or before you leave, is taxed here. Irish-source income is always taxable regardless of residence. Rental income from an Irish flat is taxed whether you live in Dublin or Denver.

For your US return none of this matters directly. The US taxes you as a citizen every year. What Irish residence changes is how much Irish tax you pay, which drives how much credit you have on Form 1116, and whether the treaty tie-breaker in Article 4 treats you as a resident of Ireland or the US in a dual-resident year. Keep a day count. Revenue and the IRS both accept a simple calendar with travel evidence, and a US citizen who cannot show days is the one who loses an argument.

The Remittance Basis: Ireland Still Has One, and What It Does for a US Citizen

The UK abolished non-dom status in April 2025. Ireland did not. If you are Irish resident but not Irish domiciled, which describes most Americans, Ireland taxes your foreign income and foreign capital gains only to the extent you remit them to Ireland. There is no charge to elect it and no time limit. Two things are always taxed in full regardless: Irish-source income, and employment income for duties performed in Ireland, even if your US employer pays it into a US bank account.

For a US citizen the remittance basis works on a narrow band of income:

• US dividends, interest and capital gains that stay in a US brokerage account are not taxed by Ireland.
• US rental profit that stays in the US is not taxed by Ireland.
• Distributions from an IRA or 401(k) that you leave in the US are not taxed by Ireland.

The catch is the savings clause. The US taxes all of that income anyway, and Ireland has taken nothing, so there is no Irish tax to credit. You simply pay US tax on it, which for qualified dividends and long-term gains is usually 15%. That is better than Ireland's 33% CGT or 40% plus USC on dividends, so for most clients the remittance basis is a genuine saving rather than a deferral.

The mechanics need discipline. Money is remitted when it is brought into Ireland in any form: a transfer to an Irish bank, an Irish card paid from a US account, or paying an Irish mortgage from US funds. Mixed accounts are the classic mistake. If your salary and your US dividends sit in one account, Revenue treats withdrawals as income first, and the remittance basis fails. Keep clean pre-arrival capital, foreign income and foreign gains in separate accounts, and remit from the capital account. Gains on assets sold before you arrived and money you had before you became resident can be brought in tax-free.

One trap is specific to the US-Ireland treaty. The treaty limits Irish relief on US-source income to income that is subject to Irish tax. Income kept out of Ireland under the remittance basis is not treaty-protected in either direction, so document it as domestic Irish law relief, not a treaty claim.

The US-Ireland Tax Treaty and Its Limits

The income tax treaty was signed on July 28, 1997, entered into force on December 17, 1997, and was amended by a 1999 Protocol. It is a good treaty, but the first thing to understand is Article 1(4), the savings clause: the US may tax its citizens and residents as if the treaty did not exist. Almost everything in the treaty that would benefit a US citizen in Ireland is switched off by that paragraph, with a short list of exceptions in Article 1(5).

The parts that still do work for you:

• Article 4 tie-breaker. If you are resident in both countries in the same year, the sequence is permanent home, centre of vital interests, habitual abode, then nationality. It decides which country is the residence state for sourcing and credit purposes, not whether you file in the US.
• Article 10 dividends. Withholding is capped at 15%, or 5% for a company holding 10% of the payer. Irish Dividend Withholding Tax is 25% by default, so file the Revenue non-resident declaration or claim the excess back if you receive Irish dividends while US resident.
• Article 11 and 12. Interest and royalties flowing between the two countries are taxed only in the residence state, which in practice means zero withholding.
• Article 18 pensions and social security. Private pensions are taxable only in the residence state. Social security payments made by one state to a resident of the other are taxable only in the residence state, and this rule is one of the savings-clause exceptions. A US citizen retired in Ireland reports US Social Security to Revenue and excludes it from US tax with Form 8833. An Irish State Pension paid to someone living in the US is taxable only in the US.
• Article 23 relief from double taxation and its re-sourcing rule, which lets the US treat certain US-source income taxed by Ireland as foreign-source so a credit can be taken.

What the treaty does not do: it does not make a PRSA or occupational scheme a qualified plan, it does not exempt the 25% lump sum, it does not protect Irish ETFs from PFIC treatment, and it does not remove your obligation to file. Any position that relies on the treaty to reduce US tax belongs on Form 8833, which carries a $1,000 penalty when it is missing. A separate 1949 treaty covers estate tax and is discussed under Capital Acquisitions Tax below.

Totalization: PRSI, US Social Security and Certificates of Coverage

The US-Ireland Totalization Agreement has been in force since September 1, 1993. It answers one question: which country's social security system you pay into. You never pay both on the same earnings.

The rules follow where the work is done, with one exception for transfers:

• Employed in Ireland by an Irish employer, including the Irish subsidiary of a US company: you pay Class A PRSI at 4.2% (4.35% from October 2026) and nothing to US Social Security or Medicare.
• Sent to Ireland by a US employer for a period expected to last five years or less: you can stay in the US system. Your employer requests a certificate of coverage from the Social Security Administration, and Revenue then exempts the earnings from PRSI. Keep the certificate. Irish payroll will deduct PRSI without it.
• Self-employed and resident in Ireland: you pay Class S PRSI at 4.2% with a 650 euro minimum, and you are exempt from US self-employment tax. Attach a statement to Schedule SE citing the agreement, and obtain an Irish certificate of coverage from the Department of Social Protection if the IRS asks.
• Sent from Ireland to the US temporarily: the mirror image applies.

Two consequences matter on the US return. PRSI is not an income tax, so it never goes on Form 1116. And exempt self-employment income does not build US Social Security credits during the Irish years. The agreement lets you combine credits for eligibility: if you have at least six US quarters, Irish PRSI contributions can count toward the 40 quarters needed for a US retirement benefit, and vice versa for the Irish State Pension (Contributory), which needs 520 paid contributions. Each country pays only for its own years.

Your Irish contributions also earn the Irish State Pension, which is 299.30 euro per week at the full rate from January 2026 (289.30 euro in 2025) and taxable in Ireland like any other income. The Windfall Elimination Provision, which used to cut US benefits for people with a foreign pension, was repealed from January 2024, so an Irish State Pension no longer reduces what Social Security pays you.

FEIE vs Foreign Tax Credit: For Ireland It Is Usually the Credit

Americans in Ireland have two ways to avoid paying tax twice on the same salary, and they are not interchangeable. The Foreign Earned Income Exclusion (Form 2555) removes up to $132,900 of 2026 wages or self-employment income from US tax, plus a housing amount above the $21,264 base. Dublin has its own higher housing limit in the IRS table. The Foreign Tax Credit (Form 1116) leaves the income in and credits Irish income tax and USC against the US tax on it, dollar for dollar, up to the US tax on foreign-source income.

The credit wins for most people in Ireland because Irish tax is higher than US tax from a low starting point:

• The 40% band starts at 44,000 euro, about $48,400, where the US rate is still 12% or 22%. Add 3% to 8% USC and Irish tax on a Dublin salary comfortably exceeds US tax at every level.
• Excess credits carry forward ten years. A large RSU vest, a US bonus or a year with US-source consulting income can use them later.
• The FEIE covers only earned income. Irish rent, ETF gains, dividends and pensions need Form 1116 anyway.
• Income you exclude does not count as compensation for an IRA or Roth contribution, and the refundable Additional Child Tax Credit is unavailable in a Form 2555 year.
• Once you revoke the FEIE you cannot claim it again for five years without IRS consent.

The FEIE still earns its place in specific situations: a first partial year when Irish tax is small, a year on the remittance basis or with SARP relief where the Irish tax on salary is lower than usual, a low-income year, or a self-employed year where PRSI is your main Irish charge and there is little income tax to credit. Some clients use both, excluding the first $132,900 and crediting Irish tax on the rest, though the credit is then scaled down in proportion.

Form 1116 keeps income in baskets. Irish tax on salary goes in the general basket. Irish tax on deposit interest, dividends, rent and ETF exit tax goes in the passive basket, and the two cannot offset each other. Irish CGT on a share sale is passive too. Convert at the IRS yearly average rate for the year, or the spot rate for one-off events, and keep the Revenue statement of liability with the return.

Irish Pensions and US Tax: Occupational Schemes, PRSAs, My Future Fund and the Lump Sum

Ireland pushes people into pensions with generous relief, and none of it is recognised by the IRS. There are four wrappers you will meet, and one new one from 2026:

• Occupational schemes run by your employer, usually defined contribution, with Irish relief on your own contributions up to an age-related percentage of salary (15% under 30, rising to 40% at 60 and over) capped at 115,000 euro of earnings.
• PRSAs (Personal Retirement Savings Accounts), which since January 2023 accept unlimited employer contributions without benefit-in-kind, though Finance Act 2024 caps the tax-free employer amount at 100% of salary.
• My Future Fund, the State auto-enrolment scheme that started on January 1, 2026 for employees aged 23 to 60 earning 20,000 euro or more with no existing scheme. Contributions begin at 1.5% from you, 1.5% from your employer and 0.5% from the State, on pay up to 80,000 euro, and step up every three years to 6%, 6% and 2%.
• ARFs (Approved Retirement Funds), the post-retirement wrapper you draw down from.

The US position for an Irish resident is uncomfortable. Your own contributions are not deductible on Form 1040. Employer contributions are additional taxable wages in the year they are paid, because the treaty has no pension contribution article like the UK or Canadian treaties. Growth inside a bona fide employer scheme is generally left untaxed as an employees' trust, but a personal PRSA with no employer link is harder to defend and some preparers report the growth annually. Every fund goes on the FBAR and Form 8938 at full value. Track your basis: amounts already taxed by the US reduce the taxable part of later withdrawals.

The lump sum is the biggest surprise. Ireland lets you take 25% of the fund at retirement, tax-free up to 200,000 euro and at 20% up to 500,000 euro. The US treats it as an ordinary pension distribution in the year received. With no Irish tax paid there is no credit, and a 200,000 euro lump sum lands in the 24% or 32% US bracket. Timing it for a year when you are no longer a US person, or drawing it in stages, is one of the few planning levers.

Regular pension income in retirement is taxed by both countries, with Ireland having the primary right under Article 18 while you live there and Form 1116 mopping up the US side. Your US accounts run the other way: 401(k) and IRA withdrawals to an Irish resident are Irish taxable, and Roth withdrawals are not recognised as tax-free by Revenue, so leave Roth money untouched until you have modelled it.

Investing from Ireland: PFICs, the 38% Exit Tax and the ETF Problem

Ireland is the home of the European ETF industry, and that is the problem. Almost every fund a Dublin broker sells is an Irish-domiciled UCITS, which the IRS treats as a PFIC (Passive Foreign Investment Company) under Section 1297, and which Revenue taxes under its own fund regime rather than CGT. You get the worst of both.

On the US side each fund needs its own Form 8621 every year. Under the default Section 1291 rules a gain or a large distribution is spread over your holding period, taxed at the top ordinary rate for each year, and charged interest as if the tax had been due all along. A QEF election needs an annual PFIC statement from the fund, which few Irish UCITS publish. A mark-to-market election is available for listed ETFs and turns each year's rise into ordinary income, which is at least predictable.

On the Irish side Budget 2026 cut the exit tax on Irish and equivalent EU funds from 41% to 38% for events on or after January 1, 2026, but kept the 8-year deemed disposal: on the eighth anniversary of each purchase you pay 38% on the paper gain whether or not you sold. There is no 1,270 euro exemption and losses in one fund cannot offset gains in another. A simpler Investment Account regime is promised for 2027, with the rate and threshold expected in Budget 2027. Until then the 38% rule stands.

The two systems also collide on timing. A year-8 deemed disposal is real Irish tax with no US event to credit it against, so it sits unused in the passive basket unless you sell within the carryforward window.

The cleaner route is US-listed ETFs and mutual funds, which are not PFICs and which Revenue generally taxes as ordinary shares at 33% CGT with the 1,270 euro exemption and no deemed disposal. The obstacle is the EU PRIIPs rule: an EU broker cannot sell a retail client a fund without a Key Information Document, and US funds do not produce one. The workarounds our clients use:

• Keep a US brokerage account that accepts a foreign address, or open one before you move.
• Hold individual US shares and Treasuries through Interactive Brokers or Degiro. Single stocks are never PFICs.
• Ask for professional client status if you meet the tests, which lifts the PRIIPs block at some brokers.

Deposit interest is simpler. Irish banks withhold DIRT at 33% and you add 4% PRSI on Form 11 if under 70. Report the interest on Schedule B and credit the DIRT in the passive basket. Revolut, N26 and Trade Republic are foreign accounts for FBAR, and Revolut's Flexible Cash Funds are PFICs.

Irish Property: Stamp Duty, LPT, Rental Income and Selling Your Home

Buying in Ireland is straightforward for a US citizen; there is no residency requirement and no foreign-buyer surcharge. Residential stamp duty is 1% of the price up to 1 million euro, 2% on the portion between 1 million and 1.5 million euro, and 6% above 1.5 million euro. Stamp duty is added to your US basis, not deducted. Local Property Tax (LPT) is an annual charge on the self-assessed value of the home, revalued on November 1, 2025 for the 2026 to 2030 period. It is a property tax, not an income tax, so it is not creditable on Form 1116.

First-time buyers can use two schemes. Help to Buy refunds up to 30,000 euro of Irish income tax and DIRT paid over the previous four years toward a new-build costing 500,000 euro or less. The First Home Scheme has the State take an equity stake of up to 30% in a new home. Both are open to Irish-resident US citizens. Watch the US side of Help to Buy: it refunds Irish tax you may already have credited on Form 1116, which requires a redetermination in the year it arrives.

If you let the property, Irish rental profit is taxed at 20% or 40% plus USC and 4% PRSI, on a Form 11. Interest on a mortgage for an RTB-registered residential letting is fully deductible, and furniture is written off at 12.5% a year over eight years. There is no deduction for the building itself. On Schedule E the US allows the same interest but also requires depreciation of the building over 30 years for foreign property, so the two profits never match. Irish tax on the rent goes in the passive basket. If you let while non-resident, appoint a collection agent or accept 20% withholding from the tenant.

Selling is where the numbers diverge:

• Ireland charges 33% CGT with a 1,270 euro annual exemption, but a full exemption for your principal private residence, with the last twelve months of ownership always covered.
• The US taxes the gain at 0%, 15% or 20% but excludes only $250,000 ($500,000 joint) under Section 121, and only if you owned and lived in the home for two of the last five years.
• The gain is measured in dollars from the purchase date, so a stronger euro creates a US gain that does not exist in euro.
• Paying off a euro mortgage when the euro has fallen creates a separate Section 988 ordinary gain that Ireland ignores.

A Dublin house bought for 450,000 euro in 2016 and sold for 800,000 euro in 2026 is tax-free in Ireland and can leave a six-figure US bill.

Self-Employment and Irish Limited Companies

The simplest structure is a sole trader. You register with Revenue, file a Form 11 by October 31 (or mid-November through ROS), and pay income tax, USC at up to 11%, and Class S PRSI at 4.2% on your profit. On the US side the same profit goes on Schedule C, converted at the yearly average rate. Because the Totalization Agreement covers you in Ireland, you owe no US self-employment tax. Attach a statement to Schedule SE citing the agreement and keep an Irish certificate of coverage on file. Irish income tax and USC then credit against the US income tax through Form 1116 in the general basket, and the credit usually exceeds the US liability.

An Irish limited company changes the analysis completely. Ireland's 12.5% corporation tax on trading profit is the attraction, but for a US shareholder it is the trap:

• A company you control is a CFC (controlled foreign corporation). You file Form 5471 every year, with a $10,000 penalty for each missed year.
• Retained profit is taxed to you currently as net CFC tested income, the regime formerly called GILTI, on Form 8992. The high-tax exception needs a foreign rate above 18.9%, so Ireland's 12.5% does not qualify. Your share of the profit is taxed on your Form 1040 in the year the company earns it.
• An individual can make a Section 962 election to be taxed like a corporation on that income, taking the 21% rate, the 40% deduction that applies from 2026 and a credit for 90% of the Irish corporation tax, which brings the current US charge close to zero. The trade is that later dividends are taxed again.
• Alternatively file Form 8832 to treat the Irish private limited company as disregarded, which puts the profit on Schedule C, avoids Form 5471 and Form 8992, and keeps the totalization exemption from SE tax. Ireland still sees a company and still charges corporation tax, but the Irish tax then credits directly against your US income tax.

Ireland adds a close company surcharge of 20% on undistributed investment and rental income, and 15% on half of undistributed professional service income, which pushes owner-managed service companies to pay salary or dividends. Salary through Irish payroll is simply employment income with PAYE and PRSI. Dividends from your own Irish company are Irish taxable at your marginal rate plus USC and PRSI, and are qualified dividends for US purposes only if the company is not a PFIC.

Directors holding more than 15% pay Class S PRSI rather than Class A, and every director must file a Form 11 even with no other income.

Capital Acquisitions Tax and US Estate and Gift Tax

Ireland taxes the person who receives a gift or inheritance, not the estate. Capital Acquisitions Tax (CAT) is 33% on the amount above a lifetime threshold that depends on the relationship, aggregating everything received in that group since December 1991:

• Group A, child from a parent: 400,000 euro
• Group B, sibling, niece, nephew, grandchild, or parent from a child: 40,000 euro
• Group C, everyone else: 20,000 euro

Budget 2026 left the thresholds unchanged. Transfers between spouses and civil partners are fully exempt, and each person can receive 3,000 euro a year from any giver free of CAT. CAT applies when the giver or the receiver is Irish resident or ordinarily resident, or when the asset is Irish property. A non-domiciled foreigner is treated as resident for CAT only after five consecutive years of Irish residence, which gives new arrivals a window.

The US taxes the giver. The 2026 lifetime exemption is $15 million per person, made permanent by the One Big Beautiful Bill Act, with a 40% rate above it. Gifts to a spouse who is a US citizen are unlimited. Gifts to a non-citizen spouse, which includes most Irish spouses, are capped at $194,000 a year in 2026 before they start using your exemption, and the unlimited marital deduction at death is unavailable unless the assets pass into a qualified domestic trust. Gifts above $19,000 to anyone else go on Form 709, even though no tax is due.

The two systems overlap badly in one direction. An American parent in Dublin who gives a child 500,000 euro toward a house owes no US tax but leaves the child with 33,000 euro of Irish CAT on the excess over 400,000 euro. Spreading gifts, using the 3,000 euro annual exemption from each parent, and the dwelling house exemption for a child who lives in the home are the standard tools.

A 1949 US-Ireland estate tax treaty, one of the oldest still in force, covers only tax on death. It gives a credit for Irish CAT against US estate tax on the same property and assigns taxing rights by the situs of the asset, but it says nothing about lifetime gifts. If you also inherit from a non-US person, Form 3520 is required for foreign gifts and bequests over $100,000 in a year, with a penalty of up to 25% of the amount if it is missed.

SARP: The Relief for Inbound Employees and Its US Side Effect

The Special Assignee Relief Programme is Ireland's inbound expat relief and the reason many US tech transfers are structured the way they are. Budget 2026 extended it to December 31, 2030 and raised the entry bar: employees arriving from January 1, 2026 need a basic salary of at least 125,000 euro, up from 100,000 euro. Those already in the programme keep the threshold that applied when they arrived.

The relief exempts 30% of employment income between the threshold and 1 million euro from Irish income tax for five consecutive years. USC and PRSI still apply to the full salary. To qualify you must have worked for the same employer or an associated company for at least six months abroad before arriving, must not have been Irish tax resident in the five preceding years, and your employer must file the SARP 1A form within 90 days of your arrival. Miss the 90 days and the relief is lost for good. Bonuses, RSUs and benefits in kind are excluded from the relievable amount, and a director holding more than 5% cannot claim.

For a US citizen the relief has a side effect that catches people out. SARP reduces Irish income tax, but the IRS taxes your full salary. An engineer on 200,000 euro who saves about 9,000 euro of Irish tax through SARP now has that much less credit on Form 1116, and depending on the rest of the return may owe the difference to the IRS. SARP is still worth having, because Irish tax on that income remains higher than US tax after the relief, but the net saving is smaller than the Revenue figure suggests and needs to be modelled together with the Foreign Tax Credit. SARP cannot be combined with the remittance basis on the same employment income.

Two related Irish reliefs are not for you. The Foreign Earnings Deduction rewards Irish residents who travel to work in listed countries, mostly outside the EU and North America, and the list does not include the US. Cross-border worker relief applies to people who commute to Northern Ireland. If your employer's mobility team mentions either, the answer is that they do not apply.

Behind on US Taxes? The Streamlined Path Back

A large share of our Irish clients arrive with several years of missed US returns, often because nobody told them citizens abroad still file. The IRS has a specific fix for this, and it is far cheaper than waiting for a letter.

The Streamlined Foreign Offshore Procedures require:

• The last three years of delinquent Form 1040s, including every Form 8938, 8621, 5471 and 3520 that should have been attached.
• The last six years of FBARs, filed electronically with FinCEN.
• Form 14653, a signed statement explaining why the failure was not willful.
• Any tax and interest due on those three returns, and no penalties at all, provided you spent at least 330 days outside the US in one of the three years.

Non-willful means you did not know and did not deliberately look away. Someone who was told by an Irish accountant that they had no US obligation, or who never lived in the US as an adult, fits comfortably. Someone who read a FATCA letter, ticked "not a US person" and moved on does not, and needs a different route.

The FATCA letters come from every Irish institution: AIB, Bank of Ireland and PTSB send a self-certification form when they detect a US place of birth or phone number, and Revolut, whose Irish customers bank with a Lithuanian entity, does the same under Lithuania's agreement. Answer them honestly. A false declaration is what converts a non-willful case into a willful one.

Accidental Americans, usually people born in the US to Irish parents who left as infants, have a further option. The Relief Procedures for Certain Former Citizens let someone with net worth under $2 million and total tax under $25,000 across the six years file, renounce, and owe nothing, without needing a Social Security number. Renouncing itself costs a $450 consular fee at the Dublin embassy, reduced from $2,350 in 2025, plus Form 8854. If your net worth is $2 million or more, or your average tax over five years exceeds about $206,000, you are a covered expatriate and pay a mark-to-market exit tax on unrealised gains above the exclusion amount, so do the streamlined filings first and renounce only with the numbers in front of you.

Key Deadlines for Americans in Ireland

Because both countries use the calendar year, the two sets of dates line up better than in most of Europe. The US dates for the 2026 tax year are:

• April 15, 2027: any US tax due must be paid to stop interest, even though the return is not yet due.
• June 15, 2027: automatic filing extension for citizens living abroad. Attach a statement saying you qualify.
• October 15, 2027: final date with Form 4868 filed by June 15.
• December 15, 2027: a further two months by letter to the IRS, granted at its discretion.
• FBAR: April 15, 2027 with an automatic extension to October 15, 2027, filed separately with FinCEN.
• Form 8938, 8621, 5471 and 8833 travel with the Form 1040 and share its deadline. Form 3520 is due with the return but has its own penalty regime.
• Estimated tax: if you expect to owe $1,000 or more after credits, quarterly payments on April 15, June 15, September 15 and January 15.

The Irish dates for the same year run a full year behind, which is a real cash-flow advantage over the UK:

• October 31, 2027: Form 11 for 2026 with the balance of 2026 income tax and preliminary tax for 2027. Filing and paying through ROS extends this to mid-November. The 2025 return's extended date is November 18, 2026.
• Preliminary tax: 90% of the current year's final liability, 100% of the prior year, or 105% of the year before that if paid by direct debit.
• CGT: tax on disposals from January 1 to November 30 is due by December 15 of the same year, and tax on December disposals by January 31. The return itself goes on the Form 11 or a CG1 the following October.
• Fund exit tax and deemed disposals: reported and paid with the Form 11 for the year of the event.
• CAT: gifts and inheritances with a valuation date between September 1 and August 31 are returned and paid by October 31.
• LPT: the liability date is November 1 and the charge for the following year is paid or a payment method confirmed by early January, or November 10 for single debit authority.
• Form 12 for PAYE workers with small extra income: October 31.

Revenue's Employment Detail Summary is available in myAccount from January, early enough to prepare the US return the same spring. A Form 11 filed in October is too late for the US return, so if you have non-PAYE income you estimate the Irish tax on Form 1116 and true it up the following year, or file the Irish return early.

A Worked Example: A Software Engineer in Dublin on 90,000 Euro

Take a single US citizen at a US tech company's Irish subsidiary on 90,000 euro throughout 2026, with a PRSA the employer pays 5% into, an Irish-domiciled S&P 500 UCITS ETF bought through Degiro, and a Revolut account. Assume 1 euro equals $1.10.

Irish tax for 2026

Income tax: 44,000 euro at 20% is 8,800 euro, plus 46,000 euro at 40% is 18,400 euro, for 27,200 euro gross. Less the 2,000 euro personal credit and 2,000 euro employee credit gives 23,200 euro.

USC: 12,012 euro at 0.5% is 60 euro, 16,688 euro at 2% is 334 euro, 41,344 euro at 3% is 1,240 euro, and the remaining 19,956 euro at 8% is 1,596 euro, for 3,231 euro.

PRSI: 67,500 euro of January to September pay at 4.2% is 2,835 euro, and 22,500 euro of October to December pay at 4.35% is 979 euro, for 3,814 euro.

Total deductions are 30,245 euro, an effective rate of 33.6%, leaving 59,755 euro net. Income tax plus USC, 26,431 euro, is creditable. The 3,814 euro of PRSI is not.

US tax, Foreign Tax Credit route

Wages are $99,000, plus the employer PRSA contribution of 4,500 euro or $4,950 as additional wages, for $103,950. Less the $16,100 standard deduction leaves $87,850 taxable. Tax is 10% of $12,400 ($1,240), 12% of the next $38,000 ($4,560) and 22% of the remaining $37,450 ($8,239), for $14,039. Creditable Irish tax is $29,074. All income is foreign, so the credit is the full $14,039 and US tax due is zero. The unused $15,035 carries forward ten years.

US tax, FEIE route

The $103,950 is under the $132,900 limit, so all of it is excluded and US tax is again zero. The difference is what is left afterward: no carryforward, no Roth IRA contribution, and a five-year lock-out if the exclusion is revoked. The engineer picks the credit.

The three traps in this return

The Irish ETF is a PFIC. It needs Form 8621 each year, and a sale is taxed under Section 1291 at 37% plus interest unless a mark-to-market election was made in year one. In Ireland it faces 38% exit tax and a deemed disposal on its eighth anniversary. Swapping it for US-listed shares, or holding it inside the PRSA, is the usual fix.

The PRSA goes on the FBAR and Form 8938 at full value. The employer's 4,500 euro was taxed in the US above and becomes basis. The 25% lump sum at retirement is tax-free in Ireland and taxable in the US.

The Revolut account is a Lithuanian bank account for FBAR purposes. Its Flexible Cash Funds would be another PFIC and another Form 8621.