Self-employed - emigrating to the USA

mcrowe

Hi all,
I'm self-employed and my business consists of selling software through my website. I just won a green card in the Diversity Visa lottery, and would like to relocate to California temporarily and see what I can learn from the tech industry there.

I'm worried about the tax implications. Here are a few details, and my understanding so far:

- I plan to emigrate on August 1st of this year
- I understand this means that I'll be a tax resident in Ireland for 2011 since I'll have been here for more than 183 days.
- From August 1st, since I'm a green card holder, when I activate the visa I will immediately be tax resident in the US.
- In order claim that I am domicile in the USA, I'll need to stay there for a full tax year (2012-2013)
- I will continue to be self-employed in the US, but will also seek full time employment as a software engineer

This means I'll be tax resident in Ireland and the US in 2011. I'm hoping that the "The Remittance Basis of Assessment" will apply in 2011 if I inform Revenue that I am no longer domicile in Ireland from August 1st. ("Split Year Relief" does not seem to apply to self-employed income)

I think this should mean that my self-employed income in Ireland will only be taxed up until August 1st so long as I'm not making any further lodgements to my Irish bank account for the rest of 2011.

The Revenue website states that:
(revenue.ie/en/tax/it/leaflets/res1.html)
"Non-domiciled individuals and the remittance basis of assessment
The remittance basis of assessment applies to foreign sourced income and foreign capital gains of an individual who although tax resident in the State for a tax year is not Irish domiciled for that tax year. Under the remittance basis of assessment, the non-Irish income and gains are taxable only to the extent that they are remitted to the State."


For 2012, I'll be non-resident in Ireland, but still "ordinarily resident", but I shouldn't be taxable on my US income since Revenue states
"the income derived from a trade or profession no part of which is carried on in the State;" is exempt.

Am I on the right track here? Does anybody have any experience with this area?
Any advice is much appreciated
Mike.

Legend100

you will more than likely be irish domiciled next year.

to be US domiciled, you would have to abandon all ties with Ireland for life (as in you are moving to the USA with no intention of coming back) it is called abandoning your domicile of origin for a domicile of choice and is quite difficult to put in place

as an irish domiciled individual, you will not be able to avail of the remittance basis of tax

With regards to the rest of your query, this is specialist advice that you require, seek professional advice

Mr. Incognito

OP Banned for a week for sheer inability to read the charter.

Legend is getting a slap on the wrist after his exam.

You want specific professional advice- pay for it. You want helpful pointers or to discuss tax matters generally feel free.