US + UK overseas inheritance - Irish tax implications

Owlet

Hello

I would welcome some advice on my tax liabilities in the following scenario:

I am a UK citizen, tax resident in Ireland for the last 2 years.

Receiving inheritance from my US citizen mother who is tax domiciled in the UK. The inheritance includes UK and US property. I understand her entire estate, including the US property, is liable to UK inheritance tax, which is based on domicile.

But I am confused about the implications for me inheriting US property from someone who is not resident or domiciled in the US. The revenue website says that if my mother was US resident or domiciled there then there would be no CAT implications for me. But she is UK domiciled so that doesn't apply. In this case, because tax will have been paid in the UK on the US property, does that help me avoid paying CAT in Ireland and IHT in the UK - i.e. is this sort of scenario covered by the UK-Ireland double taxation agreement? I would find it hard to believe I had to pay taxes on the same estate twice.

Thanks

nuac

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Leaving open for general discussion. Poster should get appropriate professional advice rather than relying on Boards.ie

Owlet

nuac wrote: »

Mod
Leaving open for general discussion. Poster should get appropriate professional advice rather than relying on Boards.ie

Oh yes i definitely will! Just curious what people think! Thanks.

Peregrinus

There's an Ireland/UK double taxation agreeement which covers CAT in Ireland and inheritance tax in the UK. In general, if you have paid inheritance tax in the UK that will be available as a credit against your Irish CAT liability. I don't think this will be different just because the property is located in the US and your mother was a US citizen.