- Non-domiciled Irish residents (were not born in Ireland, father was not an Irish resident when you were born) do not have to pay taxes on investment gains that are not remitted to Ireland
- ETF's in retirement accounts are shielded from deemed disposal, but you do pay income tax on withdrawals that are remitted.
- US-domiciled ETF's are actually not subject to deemed disposal due to the way these ETF's are set up (i.e. non-institutional investors cannot convert to underlying units). As such they are actually the *best* thing to hold (as opposed to mutual funds).
- Also Irish people are effectively barred from holding US ETFs, as in a custodian will drop you / freeze your account if they know you're residing in Ireland.
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Background: We're moving to Ireland, which has a weird "deemed disposal" rule which is basically a 41% wealth tax on ETFs and mutual funds that hits every 8 years. Gains for ETFs are also taxed at 41% (versus 33% capital gains tax for other investment vehicles) and there's no such thing as tax loss harvesting for ETFs. We plan to come back to the US eventually and mostly just want to preserve our stash.
So here's the hypothetical situation:
Let's say you had to invest a sizable portion of your FI stash in such a way that for a period of exactly 8 years you are:
- Not using ETF's.
- Employing minimal-to-no rebalancing, and no fresh money coming in.
- Track all-US stock market index performance.