Treatment of tax paid to the US on Mutual Funds

[dkelly]

I'm currently tax resident in both the US (where I live since 18mths ago) and Ireland (I'm a citizen). We have a mutual fund in Ireland. As there isn't a tax treaty between the US and Ireland for this specific type of fund, we pay US income tax on the increase in value each year (which is complete bs, but anyway...). In 6 years, Irish tax (I'm assuming DIRT?) will be automatically taken from the account.

As I will be paying tax in the US for 6 years on this account, does anyone know:

1) If I can claim the US tax paid over the previous 6 years as a tax credit in Ireland to offset the Irish tax taken in 6 years time?
2) If I should be accruing this credit somehow in my Irish returns over this 6 year period?

Thanks!

d

 

[Marc]

US taxpayers should not own European mutual funds for that reasons you state.

There is no credit against US tax for Irish tax payable and no credit against Irish tax for US tax paid leading to a high risk of double taxation despite the existence of the tax treaty beteen the two countries.

Get rid of the fund ASAP if you are liable to US tax

 

[Gordon Gekko]

There'll be no Irish tax payable if you've ceased to be Irish tax resident...are you spending 140 days a year in Ireland?