Excessive double taxation on US share bonus (RSU)?

Ning

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I got RSU (Restricted Stock Units) from my employer (large US corp in Ireland) a few years back. I am Irish resident, never worked in the US.

I calculated the total tax I paid, and this seems very high. I wonder whether there is anything wrong below, and whether I should be entitled to a refund.

They vested last year in December. I've been recently reviewing my tax affair when compiling my form 11 for 2014, and I notice:
  • 13 shares vested worth 1800 euros according to my broker in December 2014.
  • The (US) broker sold 7 of the share to pay the US federal tax for around 950 euros. I got net 6 shares. That makes a US federal tax of ca 53%....
  • On my Irish PAYE payslip for December 2014, I see the vested RSU as an income of 1670 euros + a "RSU adjustment" as deduction of 770 euros. I assume I got taxed at Irish level on 1670 - 770 euros = 900 euros @ 0.52% = 470 euros.
Meaning that on a share bonus worth 1800 euros, I paid a total tax around 1420 euros (950 euro US tax + 470 euros Irish tax), ie: 78% tax.

Does it look anywhere realistic? Should I claim a refund through form 11? Though the US authority?

A bit lost here, I cannot find any meaningful information on the topic. Most of the information I find are around dividends (taxed at 15% by US authorities).

Thanks.
 
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That doesn't sound right. The payroll tax is witheld at source in the US and your employer then transfers this to the Irish revenue. There is only one tax transaction - not two.
Shares worth 1800 EUR - your net receipt should have been approx 890 EUR. If you were taxed twice then the net would have been much lower.
 
You are into some complicated stuff here. While you have had tax withheld twice it doesn't mean that you pay tax twice. That is what a double tax treaty is for - to prevent double taxation. Basic principle is that company with primary taxing rights gets the tax and the other gives a credit for the tax paid against the tax paid in the country with the primary taxing rights. Principles of international taxation don't translate very well. You should only pay the highest tax. Link to Revenue eBrief may assist. I would start off with the stock plan administrator and see what they say. If US has primary taxing rights then Ireland should grant a tax credit for US tax. Not a particularly easy subject.

You should either get a refund in the US or Ireland for tax paid depending on who has primary taxing rights.

[broken link removed]
 
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