im in the same position in that i have held some US domiciled ETFs for some years now, some over 8 years. Nobody including revenue it seems have a definite opinion given that they are not even definitive on what makes a particular ETF included in gross roll up. Because it was clear they were not gross roll up investments when I bought them and because I have been paying tax on dividends from them throughout then they are still taxed like shares as before, (in my humble opinion).As Revenue are "withdrawing" guidance, does this mean US domiciled ETFs are now subject to deemed disposal rules, regardless of when they were purchased? If you bought said ETFs more than 8 years ago, where do you stand?
I just had a look at the history of the gross roll up regime in Ireland, they were introduced in year 2000 in order to bring Irish funds into line with their European counterparts that were also being traded on the ifsc in Dublin.Because it was clear they were not gross roll up investments when I bought them and because I have been paying tax on dividends from them throughout then they are still taxed like shares as before, (in my humble opinion).
Not really.Because US domiciled etfs were likewise purchased under a previously existing tax regime and because income tax has been paid on them throughout, there is a compelling case that that continues.
Unfortunately I've come to the same conclusion. Unless there's any convincing evidence to the contrary, I'll be selling my US ETFs before the year end.Not really.
There has been no change to the tax regime applicable to ETFs. All that's happened is that Revenue is withdrawing its guidance as to how it views ETFs that are domiciled outside the EU.
IMO the tax treatment of US-domiciled ETFs is now too uncertain to warrant continuing to hold these securities from the end of this year. Others may take a different view.