US based inheritance - CAT query/exemption

I am the beneficiary of a US estate. The disponer, my parent, was entirely US based, a US citizen, US domiciled, and had no connection to Ireland except for myself. I am a dual citizen of US/Ireland and am tax resident in Ireland. I believe I also fall under the US domicile as I appear to satisfy several of the requirements (intent, family connections, final resting place, etc). All of the estate is situated in the US.

I'm an Irish tax resident, therefore on the face of it I should be required to pay CAT on any inheritance I receive over the current threshold. However, the US/Ireland dual tax convention appears to make the inheritance exempt from this (due to the circumstances of the disponer). I've found a couple of articles online regarding this, plus a thread on this forum on a similar topic all which seem to indicate that I do not have to file or pay CAT.

Also, the following comes from the Revenue guide (IT-39) to completing the IT-38 CAT form: "Note: Particular attention is drawn to an exception to the above rules in respect of inheritances taken from U.S. domiciled disponers. Where a disponer dies domiciled in any of the States of the U.S.A., no liability to inheritance tax arises in respect of foreign property."

I have queried revenue directly about this matter (awaiting response) and am also in the process of seeking independent professional tax advice, but I'd be interested to know anyone's thoughts on the matter - it seems simple, but almost like it's too good to be true?

That would seem to imply that there is no tax if you inherit a property which is outside Ireland

@mrjimb Do you have any update on this? I am trying to figure what taxes may be implicated for an estate planning client. Clients (married couple) live in U.S. and are U.S. citizens. Client owns real property in Ireland. Client's son (presumptive beneficiary of real property) lives in Ireland and has dual U.S./Irish citizenship.

hessclaudia2 said:

. . . real property in Ireland . . .

Click to expand...

The terms of the US/IRL double taxation treaty only apply where the inherited property is "foreign property". If the client's son inherits Irish property from his parents, Capital Acquisitions Tax will apply in the ordinary way.