New York, no stamp dutyDavy 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.
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.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.
Discussed here and in several other threads.US is rather bad for inheritance taxes, assuming you are live outside the US
Covered by the key post that I linked to above.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
Are my shares now US assets and subject to US inheritance taxes?
Is there a clear definition of what is meant by a "US asset"?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
From https://www.irs.gov/instructions/i706naStock.
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.
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.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.