Best platform to trade US ETFs

stefanop

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59
All,

I'm from Italy and have been in Ireland for 4 years now since my Irish wife wanted to come back as the parents are aging. Before that we lived in the U.S. for 15 years and I still have an Ameritrade account that I opened while working in Boston (it's on my name only and it always was) and I'm not Irish domiciled (no Irish passport and have two properties in Italy and we plan to retire to Italy when the time comes and sell the Dublin home).

I sold some old shares recently and wanted to buy some US ETFs now but after I re-registered my address as EU citizen living in Europe (a few years ago), I'm unable now to buy US ETFs with TD Ameritrade because of the well known restrictions. I see from the previous discussions that there is a workaround: open a E-Toro or Tastytrade account and move the funds from Ameritrade to that new platform. Does anyone have any experience of which one is better in general? Also for me due to the tax advantage of being non-irish, non-domiciled I would need that the broker is based in the U.S. , not in Europe so that I will not have any tax implications in Ireland on the potential gains. I plan to leave the account there until I retire and then bring it to Italy not Ireland. I read that Etoro is a Israeli company but they have branches registered in Europe so that would not be good for me probably unless I can open the account with Etoro in the US.

Thanks for any feedback !!
Stefano
 
All, just for feedback.....in the end I opened an account with Tastytrade.com (it took roughly a week to get it approved and transfer 150k from the other broker TD Ameritrade) . Differently than with TD Ameritrade I'm able to buy any US domiciled ETFs without any problems, despite the fact that I'm a EU citizen residing in a EU country. The TD Ameritrade platform in my view is probably a bit better than Tastytrade (maybe because I'm more used to it...) however Tastytrade has no restrictions with buying or selling ETFs ...for now. I hope it helps.
 
All, just for feedback.....in the end I opened an account with Tastytrade.com (it took roughly a week to get it approved and transfer 150k from the other broker TD Ameritrade) . Differently than with TD Ameritrade I'm able to buy any US domiciled ETFs without any problems, despite the fact that I'm a EU citizen residing in a EU country. The TD Ameritrade platform in my view is probably a bit better than Tastytrade (maybe because I'm more used to it...) however Tastytrade has no restrictions with buying or selling ETFs ...for now. I hope it helps.
Doesn't that mean that this platform is not compliant with EU/Irish legislation/regulation on ETFs? I'm not sure that I'd be comfortable using such a platform if that's the case.
 
Gordon, yes I had the same feeling initially (it sounded like a scam) but I guarantee that I did enough research before transferring 150k to be very confident that it is a reputable company. ClubMan I haven't seen or heard of any Irish legislation or EU directive that forbids EU citizens from buying U.S. ETFs, but if you find any please share the link and I will have a look. So far it's just a Parliamentary question. I'm not saying that it will change in the future though
 
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Thanks ClubMan,

It's an interesting article. Anyway for now I will stick to the U.S. broker and U.S. domiciled ETFs then see how things develop in the future.
 
Your broker wouldn't be allowing you to buy US domiciled ETFs without the required KID information. I wouldn't really trust a broker that took such a cavalier approach to local regulation.

BTW, I presume that you realise that ETFs are subject to self assessed deemed disposal taxation every 8 years and exit tax on disposal, and not the more preferential CGT treatment?
 
and I'm not Irish domiciled (no Irish passport and have two properties in Italy and we plan to retire to Italy when the time comes and sell the Dublin home).
That doesn't necessarily mean that you're not domiciled here.
 
That doesn't necessarily mean that you're not domiciled here.
Indeed it does, I'm not domiciled here. If I have properties in Italy (an apartment rented) plus some farmland (rented as well), and an apartment that I use when I travel there, I have no Irish passport, , born in Italy, italian parents, I travel to Italy at least a few times a year, I have intention to go back to Italy once I retire, and to be deemd domiciled in Ireland I would need to have no more connections to Italy (as per the explanation in the Revenue website), this is pretty clear cut, I'm not Irish domiciled.
 
Your broker wouldn't be allowing you to buy US domiciled ETFs without the required KID information. I wouldn't really trust a broker that took such a cavalier approach to local regulation.

BTW, I presume that you realise that ETFs are subject to self assessed deemed disposal taxation every 8 years and exit tax on disposal, and not the more preferential CGT treatment?

Your broker wouldn't be allowing you to buy US domiciled ETFs without the required KID information. I wouldn't really trust a broker that took such a cavalier approach to local regulation.

BTW, I presume that you realise that ETFs are subject to self assessed deemed disposal taxation every 8 years and exit tax on disposal, and not the more preferential CGT treatment?
 
The 8 years deemed disposal rule , looks like it's only valid for the Irish/EU ETFs . See the link below table 1 page 3, where it is stated. Then it wouldn't be a concern for me anyway, since I would only be taxed if I remit the capital here, which I have no intention to do.
This is all far more complicated than you think and you’re walking yourself into trouble. For example, most ETFs don’t qualify for the remittance basis.
 
Thanks Gordon, There must be a guideline then about which ETF qualify for the remittance basis and which can't. I'm sure it can't be a secret: all I can find and understand (from the material that I read in the Revenue site, blogs etc.), is that for Irish/UK and EU ETFs (which are mostly domiciled in Ireland anyway) the remittance basis is not available, that's very clear, but for U.S. domiciled ETFs the remittance it is available, I find no other info to differentiate further. Why do you think that the remittance basis would potentially not be available for some U.S. domiciled ETFs? Are there any documents from Revenue with a more detailed explanation ? So if my U.S. domiciled Vanguard ETFs (which are all three exposed to the U.S. market only (VOO, VCSAX, VWUSX) cannot avail of the remittance basis which ones can ?
 
Ok, Gordon I did a bit more research tonight (a cold Saturday night in January at home avoiding the pub :) ) and as you say it looks more complicated that what I thought. Everything was black and white until last year (all U.S. domiciled ETFs were treated as normal income therefore taxed following the general principles of taxation, unlike the UCITS ETFs therefore the remittance basis could have been availed of). In January 2022 the Revenue has made things more complicated and there is nothing clear any more. It leaves the investor with the burden of determining if the U.S. ETFs depending on its composition should follow the offshore funds regulations (8 years deemed disposal and 41% exit tax, no remittance available) or if it should follow the normal tax principles (no tax since the remittance is available). That makes no sense that the investor has to decide, what if they have a different view ? There is zero clarity. Anyway Gordon I don't think I will get into troubles. If that's the case I need to decide whether to keep things like they are and pay the 41% tax every 8 years, 41% tax on the yearly dividends and 41% exit tax when I sell or get rid of the ETFs altogether and buy a number of single shares (the most diversified 15 or 20 shares per ETF above), it will be much riskier of course and much less diversified than owning the ETF itself but I will have zero CGT tax on the profits (if any) and 15% tax on the dividends. Tomorrow I will read more to see if those ETFs are deemed to be Offshore investments or they can go with the normal tax rules, but it will not be easy to find out as there is very scant documentation.
 
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So I had another look this morning but unforunately I have to give up. It's too complicated, there are no clear guidelines, no black or white scenario. I would also take independent tax advise, but a tax advisor would probably give me his own opinion, based on his assumptions which may be correct or incorrect since the documentation is so murky, Revenue may have a different opinion. In Italy (where normally these things are much more bureaucratic and complicated than here in Ireland) the ETFs taxation is really easy: all the ETFs independently of their domicile , composition etc. follow the same exact rules as the shares, incluging the dividends. Both dividends and CGT are taxed @ 26% that's it, but of course since I'm tax resident here I have to follow the local rules here. So what I will probably do is sell the three US ETFs at some stage this year, pay the 41% exit tax + dividend tax (if there are any gains of course) and then buy standard shares afterwards. It's a pity but that's the way it looks it is. Thanks for the replies and especially to Gordon who made me do more research on the subject since I was convinced 100% that US ETFs would still follow the CGT rule and could avail of the remittance base.
 
For what it's worth, I too was disappointed with the confusion and complexity with ETFs and the (seeming?) lack of CGT tax treatment so I gave up on them and bought Berkshire Hathaway (BRK.B) and Markel (MKL) as substitute proxy diversified market trackers. I'm not mentioning these as stock tips but just as a possible alternative approach.
 
What happens if an investor like @stefanop sells one of his US dom ETFs say VGK and pays the 41% tax because he isn't sure about the actual taxation basis but another investor deems that VGK is taxed based on CGT and revenue accepts this. Its a wonder why some accountancy firm hasn't tested this with revenue with such an example
 
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