US Pension Remittance Basis

EmilyD

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A US national, who pays taxes in the US, becomes Irish tax resident, and is subject to Irish tax based on the remittance basis on foreign source income. This individual has both a US Government pension and a US Social Security pension. Would the individual firstly consult the Ireland/USA double tax agreement to see if the pensions were taxable here. (in this example the individual would tie break for residency to the US). In accordance with Article 18 of the DTA, US social security pensions paid to Irish tax residents are exempt from tax in the US. (not sure if this applies where individual tie breaks to US for residency though). It is referred to in the Revenue TDM 35-02-04. If the pensions are deemed to be taxable here, can the remittance basis of taxation be then applied to the pensions? Thanks in advance for any insights.
 
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