Financial Intelligence
What an American moving to Ireland cannot see from the US side
Financial Intelligence is the work of finding where your money, your filings and your estate plan stop working once you become resident in Ireland, and fixing it in the order the deadlines demand. It is not tax preparation, and it is not investment management. It is the assessment that tells you which of those you need, when, and from whom.
Most people find the gaps years later, in a tax bill or a probate file. Whether you are still in the US, arrived last year, or have been here a decade, this is the work of finding them first.
Three situations this is built for
The work is the same in each. What changes is how much of it can still be done in advance.
Still in the United States
The most valuable position, because clean capital can still be identified and moved before Irish tax residency begins, and your state exposure can still be addressed while you are there to address it.
Arrived within the last year
Some doors have closed and most have not. The priority becomes what must be filed, what must be restructured, and what is quietly accruing while nobody is looking at it.
Living in Ireland for years
Usually the most surprising. Offshore fund rules, deemed disposal and inheritance thresholds apply whether or not anyone told you, and they compound.
Four assumptions we correct most often
Each of these has cost a real client real money. None of them is unreasonable. All four are wrong.
"I left the state, so I am done with state tax."
Leaving the country is not the same as leaving a state. Several US states keep treating former residents as resident long after they go, on the basis of ties most people do not think of as ties: a property, a driving licence, a voter registration, a bank account, a professional licence.
The US and Ireland have a double tax treaty, and it works. What it does not do is reach state or city level. So you can find yourself taxed by your former state and by Ireland on the same income, with no credit available against the state portion. In a high-tax state, with a city income tax on top, that is a double-digit percentage of income that nobody budgeted for.
"If I do not bring the money into Ireland, it is not taxed here."
The remittance basis is real, it is valuable, and most US citizens here qualify for it. It is also narrower than the reading above suggests, and it interacts badly with the way Americans typically invest.
Irish offshore fund rules can tax gains inside a US portfolio you have not sold and not remitted, and a deemed disposal can treat a fund as sold on its eighth anniversary whether or not you sold it. If the tax falls in Ireland and not in the US, there may be no credit to set against it. The result feels like being taxed on income you never received.
"Our estate is well under the US exemption, so we are fine."
The two systems are built the other way round from one another. The US taxes the estate and exempts a large amount per person, which is why most American families never think about it. Ireland taxes the person inheriting, and the threshold per child is EUR 400,000.
A house here, a pension here, and the number is reached without anyone feeling wealthy. A US will and a US trust drafted without Irish law in mind can also behave in ways nobody intended once Irish rules apply to them.
"We will sort the paperwork once we land."
Some of the most valuable moves expire on arrival. Clean capital has to be identified and brought in before you become Irish tax resident, and afterwards that option is gone for good.
Guardianship is the other one. Parents of young children should name who takes care of them in Ireland, immediately, in the event of a sudden death. Without it, a child can end up in protective custody while a relative flies in from the US and navigates Irish probate.
“In America an inheritance passes tax free up to roughly fifteen million dollars. In Ireland the threshold is EUR 400,000 per child, the rate above it is 33%, and it is the person inheriting who pays. Almost nobody moves here knowing that, and almost nobody already here has updated their plan for it.”
Dominick MiciottaFounder and CEO, GlobalWealth360
How the work is done
A structured intake, a working session, and a written report signed off before it reaches you. Typically three to four weeks from first contact to the finished roadmap.
A short call, free of charge
A conversation with a member of our team to understand your situation and whether the service fits. No documents, no fee, and a plain answer if it does not.
Your intake, at your pace
Your advisor takes you through a structured set of questions about your income, assets, tax history and family. Not sure is a perfectly good answer, and we come back to you on anything that needs more detail.
The Discovery session
A ninety minute working session with your advisor. Open questions are resolved, your plan is tested against your real figures, and the exposures nobody thought to ask about come to the surface.
Your report, checked before you see it
Prepared from your intake and Discovery session, then reviewed and signed off by our Chief of Financial Intelligence. Nothing reaches you until it has been checked.
Your roadmap, walked through
A follow-up call with your advisor to go through the report in order of priority: what needs action now, what matters soon, and what can safely wait.
Introductions to the right specialists
Where you need regulated tax, legal, immigration or insurance advice, we introduce you to named specialists and explain why each one suits your situation.
What the report covers
One document, written around your family and your balance sheet, not a generic expatriate checklist.
Client profile
Family structure, citizenship and residency of each member, assets, income, insurance and existing planning documents.
Risk assessment
Tax, estate, immigration, compliance and wealth transfer risk, ranked by what each one could cost you.
Immigration
How your permission interacts with working, buying a home and accessing schemes, and what changes at renewal.
Tax mitigation
Remittance planning, clean capital sequencing, state and city exposure, treaty limits and the gaps the treaty leaves open.
Compliance
What must be filed on both sides, including FBAR and FATCA, and what changes when accounts move or close.
Estate planning
Where a US will or trust breaks under Irish law, beneficiary level inheritance tax, and guardianship for minor children.
Insurance review
Life, disability and health cover read against Irish costs and Irish rules, including what your US policies still do here.
Prioritised roadmap
Actions tied to each flagged risk, in the order they should happen, with the reason each falls where it does.
Twelve month calendar
Irish and US filing dates, FBAR and FATCA, residency renewals, review points and business obligations.
Fees
Discovery and Roadmap is sold on its own. Nothing after it is compulsory, and nothing is sold to you during the report call.
FI Discovery & Roadmap
Full intake, the ninety minute Discovery session, the written report reviewed and signed off before it reaches you, the prioritised roadmap, named specialist introductions and your twelve month calendar.
Implementation
We assemble the advisory team, make the introductions and coordinate the roadmap through to completion, so you are not chasing five firms yourself.
Maintenance
Ongoing compliance monitoring, deadline management and scheduled reviews with you and your advisors as your circumstances change.
The expertise behind your roadmap
Your roadmap draws on two disciplines most firms keep apart: American tax and estate law, and Irish global mobility. Both are based here in Dublin.
Jason J. Smith, Esq.
Cofounder and Chief of Financial Intelligence
Designed the Financial Intelligence method and reviews every report before it is released.
- Yale Law School, class of 2006
- Over twenty years practising law
- PricewaterhouseCoopers alumnus
- An American living in Ireland
Primary expert voice in The Irish Times, 2 September 2026, on what Americans get wrong when they move here.
David Gilmartin
Vice President, Customer and Client Success
Leads your engagement from the first call to the finished roadmap.
- Over two decades in global mobility and cross border operations
- Founded and ran a relocation consultancy in Russia and the former Soviet states
- Client Services Director at Packimpex, Dublin
- Fourteen years with Mondelēz International across the Middle East and Europe
- Born and raised in Ireland
Whether this is for you
We would rather say so now than take a fee for a report you did not need.
A good fit
- You hold US retirement accounts, brokerage accounts or a 529
- You own property in the US, in Ireland, or both
- You own a business or hold private equity
- Your will, trust or life cover was written for US law only
- You have moved in the last three years, or you move within the next twelve months
- You know enough to know what you are not seeing
Not a fit yet
- You want a tax return prepared. We will point you to a preparer
- You want someone to manage your portfolio. That is a regulated role we do not hold
- Your assets are a current account and a pension you have already moved
- You want a free opinion rather than a structured engagement
- You need immigration permission before anything else. Start there
Questions we are asked most
General information, not advice on your situation. That is what the Discovery is for.
Do I pay Irish tax on my 401(k) or IRA?
It depends on whether you are drawing from it, whether you are Irish domiciled, and how the treaty treats the particular payment. The general shape is that the US and Ireland have agreed which country taxes what, so you should not be taxed twice on the same pension income. The detail is where people come unstuck, because the treatment of a lump sum can differ from the treatment of regular drawdown, and the two systems define a pension differently.
What almost nobody expects is that your US and Irish pensions will never merge into one pension. They are separate systems with separate rules and separate reporting, for the rest of your life.
What is deemed disposal, and does it apply to me?
Deemed disposal is an Irish rule that treats certain investment funds and ETFs as though you had sold them on the eighth anniversary of buying them, whether or not you sold anything. Tax can fall due on a gain you have not realised and cannot spend.
Whether it reaches your portfolio depends on what you hold and how Irish rules classify it, which frequently differs from how it is classified in the US. American index funds and ETFs are the usual place this bites.
Does the US-Ireland tax treaty protect me from state tax?
No. The treaty is an agreement between two national governments, and US states are not party to it. A state that considers you resident can tax you regardless of what the treaty says, and the credits available under the treaty generally do not reach state or city level.
This is the single most expensive misunderstanding we encounter, and it is entirely avoidable if it is dealt with before departure.
Do I still have to file a US tax return if I live in Ireland?
Yes. US citizens file on worldwide income regardless of where they live. If you become Irish tax resident you will be filing in both countries, and there are additional US reporting obligations on foreign accounts, FBAR and FATCA among them, which carry their own penalties for being missed.
We do not prepare returns. We establish what has to be filed, when, and by whom, and introduce you to a preparer who handles Americans in Ireland.
What is the remittance basis?
Most Americans who move to Ireland become Irish tax resident but remain non-domiciled here. That combination allows the remittance basis, under which you are taxed in Ireland on non-Irish income and gains only to the extent you bring them into the country.
It is genuinely advantageous, and it needs structuring to work. Money earned and moved before you became resident is treated differently from money earned afterwards, which is why the sequence matters more than the amount.
Is my US will valid in Ireland?
It may be recognised and still fail to do what you intended. Irish succession law includes entitlements a US will cannot override, and Irish inheritance tax falls on the person inheriting rather than on the estate, with a threshold per child of EUR 400,000.
If you hold assets in Ireland, or intend to, the question is not whether your US will is valid but whether the outcome it produces here is the one you wanted.
How is this different from hiring an accountant?
An accountant answers the question you bring them. Financial Intelligence establishes which questions to bring, in what order, to whom, and what it costs to leave each one unasked.
Most clients need both. The point of doing this first is that it tells you which specialists you actually need, rather than discovering the gap two years later.
Do you provide tax, legal or investment advice?
No. GlobalWealth360 is not a financial services firm, a tax agent or a law firm. We identify exposure, set priorities, and introduce you to qualified regulated specialists, then help you run them.
Our Chief of Financial Intelligence practises law through Smith Legacy Law. Any legal services are engaged separately with that firm.
Start with a short call
Tell us enough to know whether we can help. Every enquiry is read by a person, not a queue, and answered within one business day with times for a short call. There is no charge for that call and nothing is sold on it.
Please do not send account numbers, balances or documents. We do not want them at this stage and we do not need them to tell you whether this service fits.
GlobalWealth360 is not a financial services firm, a tax agent or a law firm, and nothing on this page is investment, tax or legal advice. The FI Discovery & Roadmap identifies exposure and priorities and introduces you to qualified regulated specialists. Jason J. Smith practises law through Smith Legacy Law. Any legal services are engaged separately with that firm and are not provided by GlobalWealth360.
Fees are quoted in euro. Figures and thresholds referred to on this page reflect rules in force at the date of publication and are subject to change.