Moving from Ireland to the US for Work: Tax Rules for PRSAs, ETFs & Savings (2026 Guide)

What Changes When You Move

For an Irish professional accepting a role in Boston, New York or San Francisco, the move is often the easy part. The harder part arrives quietly: the State Savings certificates that were tax-free in Ireland become reportable in the US, the Irish-domiciled ETF that looked like a perfect long-term holding becomes one of the most punitive assets a US tax resident can own, and the Personal Retirement Savings Account that was the cornerstone of a retirement plan needs a treaty position on a US tax return to keep its tax-deferred growth.

This article explains what an Irish professional should understand about their finances before arriving in the United States. It is written for a corporate relocate or specialist hire with an Irish occupational pension, a PRSA, some State Savings products, Irish funds or ETFs, and possibly an Irish home. The aim is to help you walk into a pre-arrival conversation with a qualified US tax preparer and a cross-border adviser already knowing the questions that matter most in a first US filing year.

The Irish Accounts That Need Pre-arrival Attention

Most Irish professionals arrive in the United States carrying a recognizable mix of accounts. An occupational pension with a current or previous employer. A Personal Retirement Savings Account, or PRSA, often opened earlier in a career. Sometimes an Approved Retirement Fund already in drawdown for a parent or an older arrival. State Savings products from An Post, Savings Certificates, Savings Bonds, Instalment Savings, Prize Bonds. An Irish-domiciled UCITS ETF inside a stockbroker account. A credit union share account that has paid a steady dividend for years. An AIB or Bank of Ireland current account. And for many, a principal private residence in Dublin, Cork or Galway kept rather than sold.

Each behaves differently once the holder becomes a US tax resident. Some continue with a treaty-based position that the US return has to document. Some lose their Irish-side tax advantage the moment US residency begins. And a handful fall into US categories that are punitive and reporting-heavy. The sections below work through the ones that come up most often.

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Retirement: Occupational Pensions, PRSAs and the Treaty

For most Irish professionals, the occupational pension or PRSA is the largest pre-arrival account. The US-Ireland income tax treaty recognizes Irish pension schemes and permits a treaty-based deferral of US tax on growth inside the scheme. In plain English: the pension can continue to compound without US tax on interest, dividends and capital gains, provided the treaty position is taken on the US return.

Contributions from the US

New Irish pension contributions typically require Irish earnings or Irish employment. Once a corporate transferee moves to US payroll and Irish residency ends, contributions usually stop. The PRSA and occupational pension do not disappear, they just stop growing through new money.

Growth and US tax on accrual

Without a treaty position, the US default is to look through many foreign pensions and tax the growth as it accrues year by year. The treaty's pension article is what prevents that outcome. Form 8833is used to disclose the treaty-based return position. In my work with Irish arrivals, missing Form 8833 in the first US filing year is one of the most common omissions.

ARF sand drawdown cases

Approved Retirement Funds raise the same treaty question at a different stage, the account is already in drawdown. Periodic distributions are treated differently to lump sums, and the country with primary taxing rights is typically tied to residency at the time of payment. Retirement-account choice for expats already in the US is covered in the retirement flagship for this series.

Investments: UCITS ETFs, State Savings and the PFIC Problem

Irish-domiciled UCITS ETFs and funds

This is the single most consequential investment issue for Irish arrivals. Irish-domiciled UCITS ETFs, iShares, Vanguard Ireland, X trackers and the rest, are almost always classified as Passive Foreign Investment Companies, or PFICs, under US rules. The PFIC regime taxes gains as ordinary income, applies an interest charge on deferred gains and requires an annual Form 8621 for each holding. A diversified Irish-broker portfolio can contain eight or ten separate PFICs. This is the biggest pre-arrival cleanup conversation for Irish-origin arrivals, and it is far better addressed before US residency begins than afterwards.

State Savings, Prize Bonds and An Post products

Irish State Savings Certificates, Savings Bonds, Instalment Savings and Prize Bonds are tax-free in Ireland. The United States does not recognize that treatment. From the start of US tax residency, accrued interest becomes reportable on the US return and Prize Bond winnings are US-taxable income. These accounts also come with US reporting obligations that the Irish-side paperwork never raised.

Credit union and deposit accounts

Credit union share dividends and bank deposit interest are taxable in the US from the residency start date. DIRT paid in Ireland generally flows through as a Foreign Tax Credit rather than being ignored, the US return still reports the gross interest, with an offset for the Irish tax paid.

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Property, Cost Basis and the Calendar Day You Land

Cost basis on appreciated Irish assets

Cost basis on appreciated Irish holdings does not reset on the day US residency begins. A share or fund bought at€10,000 and worth €25,000 on arrival has a US cost basis of €10,000, not€25,000. A sale after US residency begins is a US-taxable gain measured from the original purchase price. Many arrivals meet this point only after they have already sold something, which is the wrong moment to meet it.

An Irish primary residence, sell, rent or hold

An Irish home raises several separate questions. Sold before US residency begins, the transaction does not touch the US return. Kept and rented, the rental income becomes US-taxable with Irish tax credited through the Foreign Tax Credit, covered in more depth in the foreign rental piece in this series. Kept vacant, the property generates no US tax event until sold or let. Currency matters too: an Irish mortgage paid off during US residency can generate a US-taxable foreign currency gain under §988.

FBAR, Form 8938 and Form 8833

Three reporting forms commonly apply. FBAR, FinCEN Form 114, applies when aggregate foreign financial accounts exceed the FinCEN-published threshold at any point in the year. Form 8938 applies at higher FATCA thresholds and is filed with the US return. Form 8833 discloses treaty-based positions, including the Irish pension growth deferral. Missing FBAR carries penalty exposure far out of proportion to the cost of filing it.

The US tax residency start date

Under the substantial presence test, the default start date is the first day of physical US presence in the calendar year of arrival. Election options, including the first-year choice and dual-status filing, can move that date. A pre-arrival stock sale, a pension action or a large capital gain can land on either side of the residency line depending on the day of the move.

Irish Assets at a Glance: What Changes on US Day One

Illustrative summary of common Irish-origin accounts and their US treatment for a new US tax resident. The IRS publications and the US-Ireland treaty text are the authoritative sources for the rules in force at any point in time.

Source: Skybound 2026

Questions To Raise With A Qualified Adviser

For an Irish professional thinking through a pre-arrival checklist, questions worth raising with a qualified US tax preparer and a cross-border adviser include:

• What is my full inventory of Irish accounts, and what is each one's US treatment as a resident?
• Which of my fund, ETF and stockbroker holdings are PFICs, and is restructuring available before US residency begins?
• How should my occupational pension, PRSA or ARF be disclosed on my first US return, and who handles the Form 8833 position?
• What FBAR and Form 8938 filings will apply to my State Savings, credit union and bank accounts, including joint filings with a non-US spouse?
• Is there any pre-arrival sale, an Irish home, appreciated equity, an ETF or a State Savings maturity, better executed before US residency begins?
• What residency start-date options apply given my planned arrival date, and what does each one imply for my pension and investment timing?