Taxation of options from US employment

nest egg

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I worked for a multinational in the US for several years. Part of my annual package contained what are known as "Tradable Stock Options", which had 3 year restrictions.

I subsequently moved to the Irish subsidiary, with a new job, new title, new responsibilities etc, however within the same parent company, and therefore didn't forfeit the TSOs, despite leaving the US arm. On exercising the TSOs, you receive the difference in cash between the strike price, and the current market price (if any).

My question is whether this cash is subject to Irish taxation? My understanding was that it was, as I am now tax resident in Ireland, but having read recently on the subject, given this is income related to US employment, I am no longer sure.

I am going to seek professional advice on the subject, but it's always helpful to have a few perspectives.
 
But it's not income as say a salary would be income, if you are Irish tax domicile then it is subject to taxation in Ireland.
 
The key here is the time between when the options were granted and capable of being exercised as this generates the tax nexus under Irish rules. If you were resident in Ireland during this period then 100% of the option gain is taxable in Ireland. If you were resident in the U.S. when granted and came to Ireland during the option period then the taxable gain is time apportioned. I wouldn't describe it as particularly simple and the Revenue manual on it on it is helpful. Link is here https://www.revenue.ie/en/tax-professionals/tdm/share-schemes/chapter-03.pdf
If dealing with double tax issue talk to a specialist.
 
Just out of interest, can anyone here recommend a specialist here with US tax expertise?
 
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