Hi everyone! The complications of Ireland/U.S. migration isn't lost on any professional that has a stake in making the move work. Knowing how to treat both countries from a financial perspective is difficult - especially for those of us making the move!
In this episode, I sat down with Sean Kearney of Amvoy Wealth, a specialist in helping Irish citizens manage their US-based finances, understand tax obligations, and plan for future moves between Ireland and the US. Sean’s expertise is second to none, and his insight into the realities of balancing US and Irish financial systems is both essential and eye-opening.
In Part 1 of our conversation, Sean shares the basics of navigating dual tax obligations, the common missteps that Irish expats encounter in US financial planning, and why keeping everything above board (no matter how tempting it might be to do otherwise) is crucial.
If you’re an Irish citizen in the US, planning a move back home, or have financial assets in either country, don’t miss Sean’s advice on staying compliant, managing investments across borders, and the importance of early financial planning! And stay tuned for Part 2 in the next episode of Taxbytes For Expats!
What you'll hear in this episode:
Contact Sean:
Email: sean@amvoywealth.com
Website: https://www.amvoywealth.com/
LinkedIn: https://www.linkedin.com/in/sean-kearney-cfp%C2%AE-870763199/
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If you loved this episode or have a similar story, we'd love to hear from you! You can get in touch with us directly at info@expattaxes.ie or leave a rating and review on Apple Podcasts or Spotify.
Taxbytes for Expats is brought to you by ExpatTaxes.ie. If you're considering moving to or from Ireland and would like support with your taxes, book a consultation today: https://expattaxes.ie/services-and-pricing/.
Mentioned in this episode:
Welcome to Tax Bites for Expats, the top tax tips you
Speaker:want to know as an expat. The podcast is here to help answer
Speaker:the common queries and concerns expats have when moving to or
Speaker:from Ireland. Complex taxes explained simply.
Speaker:We'll focus on the Irish and international tax issues to be aware
Speaker:of to ensure you save time, money and stress.
Speaker:Hi everyone, Podcast producer Matt here stepping in for Steph in the
Speaker:Furious approach to the tax assessment deadline here in Ireland. Make
Speaker:sure you're on top of it too. This episode is Part one
Speaker:with Sean Carney of Amvoy Wealth. Sean is an
Speaker:expert financial planner helping Irish expats in the US to plan for their
Speaker:future and avoid the pitfalls of the tricky US Tax system and what
Speaker:Irish citizens commonly ignore regarding managing US
Speaker:Finances. In this episode we hear about Sean's
Speaker:background in financial, how he has helped people already in his
Speaker:business, and the first few major tips. For those of you considering moving to the
Speaker:US or back to Ireland, make sure you're subscribed so that
Speaker:you don't miss part two and check the show notes for more details.
Speaker:Enjoy.
Speaker:Hi everyone, welcome to this episode of Tax Bites for Expats.
Speaker:Today we are going to speak with Sean Carney of Amvoy
Speaker:wealth. Anvoy wealth is a cross border financial planning firm
Speaker:that have offices in Dublin and New York and they specialize in
Speaker:assisting Irish citizens who are classed as US Connected
Speaker:individuals, that is Irish citizens who are moving to or living
Speaker:in or returning from the us. It also includes people who
Speaker:have US based assets or those who are connected to the US by green
Speaker:card, passport or birth and we know from experience
Speaker:that includes many many of our listeners. Sean's going to talk to us
Speaker:today about some of the issues his clients encounter and how he helps
Speaker:them solve cross border financial planning problems. He was
Speaker:born in the US to Irish parents and has lived in Ireland since the age
Speaker:of two, but he currently lives in Manhattan and he has dual Irish and
Speaker:US citizenship, so he understands firsthand the issues that his
Speaker:clients face. He's also regulated to transact investment
Speaker:business in both Ireland and the us meaning he's regulated by the Central bank of
Speaker:Ireland and the Security and Exchange Commission in the us.
Speaker:And before I introduce him, he has also offered a free
Speaker:introduction call to anyone who quotes tax bytes for Expats
Speaker:podcast if they listen to this episode and reach out and contact
Speaker:him. And his contact details are going to be in the show notes. So without
Speaker:further ado. Sean, thank you for joining us. Welcome to the
Speaker:podcast. Stephanie. Thank you so much. It's an absolute pleasure to be here.
Speaker:I'm an avid listener, so, like everything, you always know when you
Speaker:hit the pinnacle of things, when you appear on things. Been watching.
Speaker:You're very kind. Well, look, thank you. Yeah, it's very
Speaker:delighted to have you. You're a rare breed of financial planner and it's great to
Speaker:have you on the show. Before we get into some of the detail that might
Speaker:be of interest in terms of what you do, tell us a little
Speaker:bit about yourself and I suppose a little bit about Envoy wealth
Speaker:and how it came to be. Yeah, well, I've been in the
Speaker:financial services, I guess, industry. I'd hesitate to call it financial planning when
Speaker:I started, but I'm in the financial services industry since
Speaker:2000. That's a lot of years now at this stage. Nearly
Speaker:25 years. Got into it in the early days working with Irish life. And it's
Speaker:pretty much a sales job. A lot about targets and selling and how we
Speaker:could, you know, get people to take out pensions, savings and
Speaker:investments, stabilize life for a number of years. Great training, set up my
Speaker:own. And about 2006 and kind of
Speaker:been on my own. Joined up with a few different people along the way, which
Speaker:has been great. But 2011, I guess, was really a
Speaker:changing point in my career in that not only were
Speaker:we in the middle of a financial crisis, but the certified financial planner
Speaker:qualification came to Ireland. I was one of the first people to go through that
Speaker:process, and I guess it made me look totally differently about
Speaker:what we were doing. Turned from a sales job to a,
Speaker:I guess ultimately a coaching job where you're sitting down with clients and you're trying
Speaker:to help them to understand what it is that life looks like and
Speaker:then how money impacts their life. So, yeah, qualified in that
Speaker:2020, I was getting a little bit, I guess, bored
Speaker:with financial planning in Ireland. You know, there's a lot of people doing. A lot
Speaker:of people doing the same thing. I had started to realize that there
Speaker:was an issue with Irish people in Ireland at the time.
Speaker:People coming home from America that had U.S. assets. They didn't know what to do
Speaker:with them. Me, as a financial planner in Ireland, didn't know what to
Speaker:do with them, you know, and I think that's a common theme across Ireland with
Speaker:financial planners, similarly here in the US So when you go
Speaker:to a financial planner or financial advisor in Ireland or in the us
Speaker:all they want is really to talk about and all they understand
Speaker:is your Irish stuff or your US stuff. But there is
Speaker:a huge Impact on cross border assets. Certainly, you know,
Speaker:we've discussed it, you know, particularly from a taxation perspective. So it's
Speaker:something I started to look at, realized there was quite a niche over here.
Speaker:The main people, I guess that deal with these cross border issues
Speaker:over here and in Ireland seem to be the. Advisory
Speaker:firms, the accountancy firms. The problem with them is
Speaker:they deal with the high end of high net worth individuals.
Speaker:So there's a whole level of people kind of below these
Speaker:that are getting no advice. And it goes back to that old
Speaker:adage. The biggest issue that we have is that we don't know what we don't
Speaker:know. So for the majority of these people, me included at the time,
Speaker:as a US citizen, I didn't understand fully the
Speaker:impact of being required to do a tax return to the
Speaker:IRS on an annual basis. So I started to look at what
Speaker:that would look like. I had no idea to ask about it because nobody was
Speaker:doing what it is that I wanted to do. So I undertook probably the
Speaker:craziest thing that I've ever done that I just want to set up
Speaker:an advisor firm in the US and get it registered with the
Speaker:SEC and that I would run that in tandem with the Irish firm that I
Speaker:had running with the Central Bank. Four years down the line, a lot
Speaker:has changed. I would love to have known four years ago, well, I know now
Speaker:because I'd have done a lot of things differently, but it's been an
Speaker:unbelievable journey, it really has. And I guess it's culminated with
Speaker:18 months ago I moved here to New York, living in Manhattan.
Speaker:I'm living the dream. Ideally I'd love to be 20 years younger over here.
Speaker:It's an amazing city for lots of reasons. You know,
Speaker:pace to get up and go about people, you know, if business is
Speaker:what you're looking for, this is where you come. I'd love to have the energy
Speaker:of a 25 year old to put into what I have. But yeah, I'm
Speaker:making a goal but now and I really love what I. Do over here and
Speaker:I'm sure, Blake, yeah, that takes bravery. And I know you said, you know, you
Speaker:look back and think, oh, I wish I'd known. But that's part of the journey,
Speaker:isn't it? You learn as you go. And it's not a path that's very well
Speaker:trodden because we would often hear clients say to us when they come and they
Speaker:ask tax questions, well, who can I speak to about the cross
Speaker:border financial issues? And the short answer is there isn't that many
Speaker:People that I'm aware of who are operating in the space that
Speaker:you're in. So congrats for carving out a very successful
Speaker:niche. Tell us about the people that you've worked
Speaker:with to date. How do they find you and why do they come to work
Speaker:with you? Yeah, I guess the main people that I'm concentrating on now,
Speaker:what I have the Irish business and I have the US business. The US business
Speaker:is my core business at the minute and it's what I'm really trying to concentrate
Speaker:on and grow. You know, the Irish diaspora, the Irish network over here. You
Speaker:have two very different, I guess, nationalities walk
Speaker:and living side by side. The US people absolutely love
Speaker:themselves. I love that about them. The most confident, the most
Speaker:brash, the loudest people you're ever going to meet are the people that you see
Speaker:in New Yorkers. The problem is they walk across you to get
Speaker:to their destination. Both physically and metaphorically. The
Speaker:Irish people are a lot kind of closer. They've all
Speaker:traveled a fairly similar path. They've all come over here to a strange company away
Speaker:from home and they've all, I guess, had to
Speaker:start from scratch and build something from there. And even the likes
Speaker:of people that have come into, you know, tech and into the
Speaker:pharma and into the, you know, the bigger construction companies over here, it's
Speaker:all starting again when you come over here. So the Irish diaspora over
Speaker:here is very close. The network is brilliant. And that's what I've
Speaker:started, I guess I've started to look at and I've had some great help
Speaker:from various different networking groups over here. And Irish people,
Speaker:thing about the Irish people over here is they love to help you and they
Speaker:genuinely mean it. The Americans genuinely mean
Speaker:they'll help you so long as they can get something out of you and would
Speaker:probably take whatever you were looking for off you. And I don't mean that in
Speaker:a bad way. That's just the way it is over here. The Irish people are
Speaker:genuinely here to help. So I've used a lot of that and
Speaker:started to build up a really good network around that. I guess what I found
Speaker:is, which is what I thought I knew before I came over,
Speaker:is there is no alternative. There really isn't. I am
Speaker:sitting here. You talk about a needle in a haystack. You know, there
Speaker:are thousands of Irish US
Speaker:connected people with assets in Ireland or assets in Ireland than the
Speaker:US who are thinking about moving home or thinking about moving over
Speaker:and they're not getting proper advice. And actually, you know what, as
Speaker:you Say that it makes me think when we left Australia,
Speaker:I'm not going to pretend one of the top things on my list was what
Speaker:do I do with my Australian pension, my super. It was just one of the
Speaker:things I was. Okay, I'll think about that afterwards. Talk to us about
Speaker:why that might be more of a problem for some of your clients because of
Speaker:their connection with the us I suppose from an Aussie perspective, it's not as big
Speaker:a deal, but tell me why or tell people who don't understand why. Is that
Speaker:a problem to potentially do that? Look, I guess people are leaving the us.
Speaker:Irish people are funny. And again, it may sound like, I mean down on Irish
Speaker:people. I was born in America, but I consider myself Irish. I love
Speaker:Ireland. I love it over here, but I don't think I'll be over here forever.
Speaker:And so when I talk about things that I feel that Irish people do
Speaker:wrong, you know, it's to try and get them to understand that and
Speaker:try and get them to do something about it. People come over here to America,
Speaker:they build up assets over here and they move back home and they
Speaker:assume that it's just another bank account or it's just another investment account
Speaker:that they have in the US and that's the way they consider because again, they
Speaker:don't know any better. They don't understand the implications. The
Speaker:reality is, particularly if you're green carded or if you're a citizen
Speaker:over here, there are issues around, I guess, taxation and
Speaker:requirements that you need to do on an annual basis. The reality
Speaker:is if you move back home and you are green carded or you
Speaker:are a US tax citizen or a citizen, you need
Speaker:to do a tax return on an annual basis. So just
Speaker:going home and parking stuff can have huge
Speaker:implications down the road if the IRS come knocking on the
Speaker:door. It's funny, I think we've discussed this before. One of the
Speaker:main places people get their financial information
Speaker:when they're moving from one country to another is online. And I don't mean
Speaker:Google, which is bad enough, but you see people asking questions
Speaker:on Facebook that they have no business really asking on Facebook. They should be
Speaker:asking people that understand fully. So, again, look, you've
Speaker:probably seen it. There's Facebook groups out there and they're brilliant, they really
Speaker:are, for raising awareness of what needs to be done.
Speaker:But somewhere like that is not going. Just because somebody did
Speaker:something with a 401k before they left the US to go back
Speaker:to Ireland doesn't mean A, it was the right thing and B, it certainly doesn't
Speaker:mean that they're qualified to give you advice. Totally. And you
Speaker:know, even from a tax perspective, we talk about the surely category,
Speaker:but surely this is the answer. And you know, usually that advice has been given
Speaker:to somebody from their friend, very well meaning friend. And that's not to say it's
Speaker:wrong, but it's also not to say it's right. So your point is very
Speaker:valid. And I think, you know, what people don't see and what we see
Speaker:more of probably as advisors is I suppose, the
Speaker:sophistication around the ability for different
Speaker:governments, particularly the US to share information and gather
Speaker:information from other institutions globally. To your point, I think
Speaker:you're spot on. A bury your head in the sand approach might
Speaker:be okay, but it isn't wise. And it also might not be okay
Speaker:forever. Proactively speaking, you know, somebody listens to that and
Speaker:think, oh, do I have a problem? What does working with you
Speaker:look like? Because obviously there's, you know, the aspect of let's do this right.
Speaker:What is, what's the overall aim that you want someone to achieve when they
Speaker:come to you? Yeah, I guess I can over here, going
Speaker:back to the whole circle. Financial planner and I use cash flow
Speaker:forecasting software when I deal with clients. You know, when I was in Ireland, it
Speaker:was very simple. You sat down with a client and they were able to say
Speaker:to you, you know what, it's 47 years of age, I work here, here's my
Speaker:assets, here's my expenditure, here's my liabilities. Plan me
Speaker:out for the rest of my life. And that's very simple to do because we
Speaker:can use cash flow forecasting. It's never going to create a plan that's exactly spot
Speaker:on. We use assumptions in it, but it allows us to get as close as
Speaker:we possibly can to what your future cash flows are going to look like. A
Speaker:lot of people I meet over here, one of the questions they're asking is because
Speaker:everyone that comes to the US from Ireland genuinely believes
Speaker:they're going home. Not, maybe not everyone, majority of people genuinely
Speaker:believe they're going home. The future, the reality is that life gets in the
Speaker:way. And if life doesn't get in the way, they just stop thinking about
Speaker:it. And days run into months, run into years, run into decades, and the next
Speaker:thing you're 50 or 60 and you still haven't got home. The main reason I
Speaker:find people don't go home is because they don't think about it or they don't
Speaker:plan to go home. So I guess from my perspective, when somebody comes to
Speaker:me here, the very first thing that I like to do or that I think
Speaker:they should do is to try and understand what the next 5, 10, 15,
Speaker:20 years are going to. You know, my process, you know, when people
Speaker:come to me, they get a little bit confused because I
Speaker:don't start talking about money, I don't start talking about investments. I don't
Speaker:start talking about, you know, give me your 100,000, I'd invest that.
Speaker:And we get this time, 10 years, we'd have 57
Speaker:million in a bank account. You'd be rich. For me, it's about trying to understand
Speaker:what does your future look like? What do you want it to look like? That
Speaker:makes perfect sense because ultimately these are people who
Speaker:are in the middle of making a big life decision. Yeah. So therefore, you know,
Speaker:the questions relating to what you want, it's not necessarily, oh, I'm coming to you
Speaker:because I want extra turn. They're coming to you because they're about to do something
Speaker:in their life that is a big deal. I think your questions are very sound,
Speaker:very astute. I know, absolutely. But people tend not to think about that
Speaker:way because to them there's two things, my life and my
Speaker:money. And the two of them go hand in hand. They absolutely go hand in
Speaker:hand. But unless you understand what your life is looks like or what your life
Speaker:wants to look like, then the money doesn't really matter.
Speaker:Because if you have a pot of a million or you have a pot of
Speaker:20 million, if you don't understand what you need that money to do in the
Speaker:future, then you have no real idea of how you can spend it. So
Speaker:when clients come to me, if I can get them to understand, you know, okay,
Speaker:I'm here, I'm going to stay here for five years and then I want to
Speaker:look at going home to Ireland. We can plan out five years here and then
Speaker:we can plan the exit. The exit is the important piece. You know, planning in
Speaker:Ireland and planning in the US are pretty much the same. Planning
Speaker:is a universal thing. Okay. Where I want to live, where I want
Speaker:to work, how many kids I want to have, what age my kids, what am
Speaker:I spending my money on, what do I want to drive, where do we want
Speaker:to go? All these things are universal. What you want to do in America is
Speaker:probably similar to what you want to do in Australia, what you want to do
Speaker:in Ireland. It's, it's understanding what that is and then
Speaker:layering the money back in and trying to understand, well, you know, if we have
Speaker:X pot of money, how does that change or how does
Speaker:that fund what we want to do on this side? But the key
Speaker:piece that they need to look at is if they want to go home, what
Speaker:do we need to do? And I guess the tax piece is, there's no
Speaker:question of all of this. The tax piece is the most important piece
Speaker:because it's the piece they can either make or break their plan even though they
Speaker:don't understand it. Because if they don't look after that piece property, they could
Speaker:have a knock on the door in 5, 10, 15, 20,
Speaker:50 years time from the IRS going, you didn't do
Speaker:something 50 years ago. And you know what we're going to do? We're
Speaker:not going to take the money you had 50 years ago and look at that,
Speaker:we're now going to look at the money you have now 50 years later, which
Speaker:could be considerably more. And that's what we're going to start drilling down into. That's
Speaker:what we're going to start taxing on. They're the bits, I guess, that people need
Speaker:to. So I think I'm incredibly important in people's
Speaker:lives and in people's process. And what does it force me to admit somebody
Speaker:else is if somebody came to me and they said, I've only time to talk
Speaker:to one person, you or somebody else, I would send them to you
Speaker:for that pure and simple reason that that bit is actually more important because that's
Speaker:the piece they could explode their life. Simple things. And he asked me earlier,
Speaker:I guess I've spoken around in circles about, you know, when people are leaving
Speaker:the U.S. what do they need to be taken in mind? If you're not green
Speaker:carded or you're not a citizen, it's not
Speaker:as big a deal. But for people particularly green carded, and these are the people
Speaker:that I kind of see that don't look much into it because what they do
Speaker:is they come over here and the first thing they want to do is get
Speaker:a green card. It's an Irish thing because it goes back years, probably goes back
Speaker:to the 80s when green card was considered the golden ticket. Get a green
Speaker:card, you could get out of an Ireland that had no money, you could go
Speaker:to the US and you could make a life for yourself. And New
Speaker:York is, you know, it's living proof of that. The amount of people I'm meeting
Speaker:over here that came over here in the 80s that have made huge money,
Speaker:have done incredibly well for themselves in reality stuff, they wouldn't have done
Speaker:at home and that's fine. These people are probably here for life. But you have
Speaker:people that come over and go, I want a green card. The implications of having
Speaker:a green card are quite considerable. And you know, you
Speaker:absolutely shouldn't get a green card just because you think you want
Speaker:one. You need to sit down. There are great
Speaker:immigration attorneys over here that you should sit down with. Some of them will
Speaker:allow a 15, 20 minutes initial meeting for free.
Speaker:Anything you can get for free in the US is amazing. But you know, have
Speaker:these meetings to understand the implications because a lot of people
Speaker:will come over here, get a green card and then leave. If you leave under
Speaker:certain situations, that is time with the green card, a lot of people
Speaker:go, I'll just go home and keep my green card and say nothing because it'll
Speaker:go out of date. An hour date green card is the same as an out
Speaker:of date passport. You're still considered to have a green card, but you
Speaker:have none of the benefits. You can't travel back in and out of the country,
Speaker:but what the IRS can do is they can still tax you
Speaker:and you should still be doing a tax return. So part of an exit
Speaker:process of a green card is, is that you sit down,
Speaker:you explain that you're leaving the country, they will assess you
Speaker:financially and if you hit certain thresholds, you may have
Speaker:to pay tax on assets and investments. As people, we go,
Speaker:no, I'm not doing that because I don't want to pay tax. I think you'll
Speaker:agree one of the things that you should do before you leave the US with
Speaker:investments is rebase them and pay any taxes due on them
Speaker:because CGT is lower up here than it is. Again,
Speaker:these are the reasons that people should always vote you for this simple.
Speaker:Things just as well. Just to kind of not out one point
Speaker:that you said there that that may be an assumption if someone's listening
Speaker:to that. In that example you just gave of somebody having
Speaker:potentially to pay a tax to the US on exit for whatever reason.
Speaker:There is no credit mechanism in the Irish US treaty for that.
Speaker:So I suppose what we have there is very, very
Speaker:solid example of when this does go wrong. And I have seen
Speaker:it go wrong once in practice, thankfully only once. And it
Speaker:went fairly badly wrong for the person two people in question. But
Speaker:the point is this can have fairly bad outcomes from a tax
Speaker:perspective. And the very simple thing is this. It probably was very
Speaker:easily avoided because it is about. You say this
Speaker:constantly. Plan in advance. Plan in advance also as
Speaker:well. Just in this conversation, one Thing that you said that struck me,
Speaker:that we see quite frequently is like we're talking here about green
Speaker:card holders, but what about the fact that maybe they've married a US citizen on
Speaker:the way out or if they're coming back, do you know what I mean? So
Speaker:my point is, you know, so do you work with that
Speaker:cohort? So let's say you've got an Irish person who went over, they had a
Speaker:green card, they hand it back or they don't, whatever, they've gotten married to a
Speaker:US citizen and they as a cohort are coming back to Ireland. Do you service
Speaker:them as a married couple? Let's say, yeah. No. And again,
Speaker:the more complex you can make yourself, and I don't mean that in a bad
Speaker:way, an Irish person getting married to a US citizen is,
Speaker:it's not an issue in real life, it's an issue from a tax
Speaker:perspective, from an estate planning perspective. All these things end up
Speaker:becoming an issue. Now, as you said, not a big issue because they can easily
Speaker:be sorted. They become an issue if you don't sort them out before
Speaker:you leave or after you leave and start to do the stuff that you're
Speaker:obliged to do, legally obliged to do. Because the last thing you want is
Speaker:the IRS to come knocking on your door down the road. And the IRS don't
Speaker:mess around. I didn't know or I forgot
Speaker:or nobody told me that. It's probably not something that's going to
Speaker:make the IRS go out. If you didn't know, then we don't care. They don't
Speaker:mess around. And the reality is they have the power, to the best of my
Speaker:knowledge, and you can't correct me on this if I'm wrong to go into your
Speaker:IR's bank account and pretty much take money out of your Irish bank account, you
Speaker:woe to them. I can't verify that, but I would believe it.
Speaker:The powers that tax authorities have are probably
Speaker:often more far reaching than we would like to believe.
Speaker:And I think the point I would make is in terms of, I
Speaker:suppose, cross border reporting and you know, things like FATCA and the
Speaker:common reporting standard that we see, these are all basically acronyms for
Speaker:processes that are in place to allow financial institutions
Speaker:on an international level to share information with governments and
Speaker:tax authorities. So you know, sometimes people will say to us, well, nobody will
Speaker:know if I don't say it. And somebody said to me once, I really like
Speaker:the analogy, it's like, well, yeah, you know, you could step
Speaker:out on the road and you might not get hit by a bus. But I'm
Speaker:not going to tell you to look, step on the road without looking in case
Speaker:it happens. So the point is, it's. We're talking about self assessment here. You
Speaker:know, your obligation is to declare and
Speaker:you'll be penalized if you don't. That's what we're saying. So
Speaker:be proactive. It's never an issue until it becomes an issue. And that is the
Speaker:piece. And it's simple. I guess the issue that I have, and it's a similar
Speaker:issue that you have, is that there's not enough of you or
Speaker:me. And in general, Irish people particularly are terrified
Speaker:of competition. I would love if there was more of me for
Speaker:the pure and simple reason that there's more clients that I'll ever be able
Speaker:to service over here on varying different
Speaker:levels. And I have to prioritize, therefore I have to charge
Speaker:fees. Some people won't pay fees and this again, not beating the
Speaker:Irish people. But the Irish people in general
Speaker:hate paying for any fees. To them, they
Speaker:will genuinely value something
Speaker:that's perceived as free, particularly in this
Speaker:industry, a free financial review. No problem doing
Speaker:that. I'm going to charge you a fee. And it's going, hey, hold on a
Speaker:minute. I'm not sure I want to do that. You know, the
Speaker:fees that people will pay, certainly you and me,
Speaker:is far less than the penalties down the road for not doing or not
Speaker:doing property. I go further than that and I say
Speaker:that you can pay a fee and save money or you can not
Speaker:pay a fee and pay money like that usually works out like that. Usually it's
Speaker:very, very rare, very rare that a client doesn't recoup the cost of the. So
Speaker:view it as an investment. And I think, you know, financial planning,
Speaker:investment, these are people who have investments, they understand the concept of
Speaker:investing well. If they're not willing to invest in something simply because it doesn't
Speaker:come with, you know, an asset and a brokerage statement, perhaps the disconnect is there
Speaker:between the right client and your service. But I would
Speaker:imagine if anybody listens to the
Speaker:complexity of trying to understand how
Speaker:to offer advice that you offer across border, perhaps then they would
Speaker:understand why a cost comes with a fee. Tell me, answer this question for me
Speaker:because this is a question that's not easily answered. Clients
Speaker:will very often say to me, and I don't need you to give all your
Speaker:trade secrets away. Clients will very often say to me, oh, you know, leaving the
Speaker:US my investment account
Speaker:manager or my kind of service provider, they want me to update my address.
Speaker:And I've put in that I'm now living in Ireland and they've come back and
Speaker:told me that I can't invest with them anymore. What do you say to somebody
Speaker:who said that to you? Because we hear that a lot. Yeah, yeah. Now
Speaker:again, there's one company out there in particular that if you tell them
Speaker:that you are no longer going to be resident in the U.S. particularly if you're
Speaker:going back to Ireland, they will write you a check for your account. Not that
Speaker:simple, but they'll send it straight out. And this includes
Speaker:401ks. You tell this company that you're moving back to Ireland.
Speaker:Retirement accounts here in the US are done slightly different than retirement
Speaker:accounts in Ireland in that if you take funds from a
Speaker:life company in Ireland, cash in a pension area, the life company will
Speaker:deduct tax from it. Over here, you get the gross number out. So if you
Speaker:have a million euros in a 401k and the investment company
Speaker:doesn't want you investing with them anymore because they're moving back to Ireland, they will
Speaker:send you paycheck for the full value of your fund
Speaker:and the onus will be on you to pay the tax on that. Now, some
Speaker:of us are very cute Irish people. We think we get away with paying no
Speaker:tax and that and we go home and we cash it or we forget to
Speaker:put the pay the tax on it. But again, I'm not
Speaker:saying you will be, but you could be caught up. And if you are caught
Speaker:up, you'll probably lose the whole million euros or
Speaker:million dollars. And possibly then. So
Speaker:that is an important piece. What would you say to that person?
Speaker:Okay, so that example, somebody says, I've come back. Let's say they come
Speaker:back with a million. I can't imagine there's. Oh, well, you should do this.
Speaker:It's a process, isn't it? It's, it's the sitting down, it's the figuring
Speaker:out. I mean, obviously they probably don't want a million in cash. Yeah, it
Speaker:totally is. Just. Sorry. And I guess just two things on that. What do I
Speaker:advise people to do? If you have a US address,
Speaker:you'll need a US correspondence address for the majority
Speaker:of investment houses to allow you to continue to invest with it. So again,
Speaker:something to look into. I'm often asked the question, do I leave my money in
Speaker:the US or do I bring it home? And I guess that's not a
Speaker:simple yes, no, it's not a one size fits all. That's where
Speaker:the planning piece comes in do you ever intend going back? What do
Speaker:you need this money for? There is a piece of advice and I
Speaker:have advised people to withdraw their 401k before they go
Speaker:home, pay the tax on it, the simple thing, and going back to again, you
Speaker:know, what payout will they get in exchange for paying their
Speaker:fees, say to the likes of you? If somebody comes to you and says they
Speaker:have a million euros in a brokerage account, I've sat it, sat there for the
Speaker:last 10 years or whatever. I started off with 500,000,
Speaker:so my growth, 500,000, you know, their CGT to be paid
Speaker:on that. The rate of CGT in the US is considerably
Speaker:lower than the rate of CGT back in Ireland, usually
Speaker:between 15. To 18% depending on which is a. Lot of
Speaker:half a million. It's a lot of growth, isn't it, to give away. Yeah.
Speaker:So from your perspective, I assume one of the first piece of advice you'd be
Speaker:given them is rebase that, pay. Your cgt and also just one
Speaker:point there. Right. So they're not just rebasing the growth in the asset, they're
Speaker:actually, and this gets a bit complex, but it's important, it's worth mentioning. They're also
Speaker:effectively rebasing for better or for worse, because obviously it depends the
Speaker:FX movement over that period. Because the Irish capital gains
Speaker:tax is calculated with reference to spot foreign exchange rates which have moved
Speaker:over time. So we could see, you know, a U.S. gain on
Speaker:paper of like $100. But when you convert that to euro using the
Speaker:appropriate exchange rates, it can potentially augment again. The point
Speaker:being this can save, you know, a lot of money if when you
Speaker:compound the tax with whatever the foreign exchange conversion
Speaker:throws up, people often don't appreciate that point until the calculations shown
Speaker:to them and look at what this actually is. But yeah, that's a very simple
Speaker:thing to do and you know, the timing, the appropriateness of
Speaker:it. This is then when really what we're looking
Speaker:at is somebody in the middle to kind of coach
Speaker:people about the right decisions, be able to offer them investment
Speaker:solutions. Because just be really clear here, not everyone can
Speaker:do this and offer investment solutions. And then a US advisor and an Irish
Speaker:advisor from a tax perspective who both speak to each other like, we've seen
Speaker:that, haven't we? Where when that happens, it works really, really well.
Speaker:And people, what do they get? I mean they get confidence, they
Speaker:get clarity and they save a lot of money. Who doesn't want
Speaker:that? That's perfect financial planning.
Speaker:Thanks for listening to tax bites for expats, Please do leave a
Speaker:rating or review wherever you listen to your podcast. And as always,
Speaker:remember to take professional tax advice specific to your
Speaker:personal circumstances before acting or refraining from action
Speaker:in connection with the matters dealt with in this series. The material
Speaker:in this podcast is intended to give general guidance only.