What do CRH shareholders need to do in advance of listing moving to NYSE?

B

boltownes

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Davy provide 2 options for CRH holdings when it leaves Euronext- you can opt for LSE or NYSE. I'd be grateful for views on which you think is better. Thanks.
 
CRH trade on Dublin/ISEQ, London/LSE and NYSE.
Aren't they moving their primary listing to NYSE?


If so then that might offer the best option as far as liquidity is concerned.
But you might want to check in case holding it there involves any witholding taxes or other tax issues.
Usually a non US national can avoid or reduce US witholding taxes by filing a W-8BEN via their broker.
www.investopedia.com

W-8BEN: When to Use It and Other Types of W-8 Tax Forms

Learn about W-8BEN, W-8BEN-E, W-8ECI, W-8EXP, and W-8IMY, which show an individual or business receiving income in the U.S. is a foreign entity.
www.investopedia.com www.investopedia.com
 
ClubMan said:
But you might want to check in case holding it there involves any witholding taxes or other tax issues.
Usually a non US national can avoid or reduce US witholding taxes by filing a W-8BEN via their broker.
Click to expand...
There was a similar discussion a while ago about Irish companies directly listed in America, but I'm not sure if it was definitively resolved. If CRH is remaining an Irish company, just with its primary listing on the NYSE, then I imagine there should be no change from the current taxation, with no US withholding and no W-8BEN required. It seems that it is possible for companies to do this without going the ADR route, as there are other companies that are Irish to reduce taxation but have their primary listing on the NYSE, such as Seagate, that I think are subject to Irish withholding taxes, not American ones. I don't know any more about it, though, so, as @ClubMan says, it would be important to check.
 
Babhdan said:
US is rather bad for inheritance taxes, assuming you are live outside the US
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Discussed here and in several other threads.

Key Post - Be careful if you hold more than $60,000 in US equities

Of course what most people don't appreciate is that if you are not a US citizen or US resident and you hold more than $60,000 in US equities then US estate taxes apply to transfers between spouses on death. That's right if you die your spouse or civil partner would have to pay US Estate taxes...
www.askaboutmoney.com
 
Has Davy or any other stockbroker or, indeed, CRH, provided any advice on this?

I have shares in CRH held in share certificates and have just received a long communication from CRH which I need to study.

1) I must complete a US tax Form W-8 or W-9 .
If I don't , the dividends will be subject to US tax and net dividend will be paid by way of a cheque in US$
2) I assume that by completing this form, I will be exempt from the US tax and everything else will continue as normal.

But I need to study the documents in full. It would be very helpful if CRH or someone else provided a guide for the individual investor.

Brendan
 
The US will deduct 15% of the gross dividend as they are allowed to by the double taxation treaty.

You will get a tax credit for this from Revenue and only be taxed a further 5% or 25% depending on your tax band
 
@jpd

Thanks

So there is not disadvantage from a dividend point of view. Just a bit more complicated.

Are my shares now US assets and subject to US inheritance taxes?

Brendan
 
Yes, if the estate has assets over $ 60,000 (I think that's the limit) then the US Revenue can get taxes on shares held in US companies or other US assets even if they are held outside the US eg in Davys or Degiro - in reality, I don't think they are going to chase your estate for these unless you have millions at stake - € 50,000 in Microsoft or CRH won't be chased, imho
 
jpd said:
Yes, if the estate has assets over $ 60,000 (I think that's the limit) then the US Revenue can get taxes on shares held in US companies or other US assets even if they are held outside the US eg in Davys or Degiro - in reality, I don't think they are going to chase your estate for these unless you have millions at stake - € 50,000 in Microsoft or CRH won't be chased, imho
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Covered by the key post that I linked to above.
 
Brendan Burgess said:
My question is whether my CRH shares are now US assets.

Just because they are quoted there does not definitely mean that they are US assets

Brendan
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Is there a clear definition of what is meant by a "US asset"?
A share in a company quoted on a US exchange?
A share in a company with its primary or only listing on a US exchange?
A share in a company headquartered in the US?
A share in a company that does most of its business in the US?
Something else?
 
That is why I asked the question. I don't have a clue either.

It's clear than Berkshire Hathaway and Microsoft are US companies.

I have no idea if CRH is.

Brendan
 

Stock.​

Generally, no matter where stock certificates are physically located, stock of corporations organized in or under U.S. law is property located in the United States, and all other corporate stock is property located outside the United States.
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From https://www.irs.gov/instructions/i706na

There is a lot of info on this site - but it is a lot
 
jpd said:
stock of corporations organized in or under U.S. law is property located in the United States, and all other corporate stock is property located outside the United States.
Click to expand...
This sounds to me like shares in companies registered in Ireland, such as CRH, Accenture, Eaton, Seagate, etc., are "property located outside the United States" even if the shares were purchased on the NYSE, and so the USA would not have any involvement in inheritance if the shareowner dies. Can anyone who knows more about these things confirm? It seems important to establish that this is definitely the case.

Also, it appears that I was wrong earlier when I guessed that a W-8BEN would not be required for such companies. Eaton, another company that is registered in Ireland but traded on the NYSE, says that although the dividends are subject to Irish dividend withholding tax, "https://www.eaton.com/gb/en-gb/company/investor-relations/Irish-Dividend-Withholding-Tax.html (A W-9 or a W8-BEN is still required to avoid United States Dividend Tax withholding)". It does say "avoid", though, so it seems that it is at least not the usual situation where for Irish residents a W-8BEN will just reduce the US withholding to 15%.
 
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