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The Global Insight

Is US tax due on Irish inheritance?

Author

Sarah Garza

Updated on April 02, 2026

The operation of the Ireland US treaty only extends to inheritance tax in Ireland and federal tax. There is no special arrangement for gifts. US federal tax is levied on the transfer of the estate of every person who is a citizen or resident in the US, subject to a current threshold of $5,450,000.

Do beneficiaries pay estate tax?

If you are a beneficiary, you will not have to pay tax on your inheritance. There are a few exceptions, such as the Federal estate tax. With the exception of the estate tax for estates exceeding $11.58 million dollars per person, California does not have a state-level inheritance tax.

How much can you inherit without paying taxes in Ireland?

Under the current rules, more than €1 million can be left, free of tax, by parents with three children, giving a tax-free threshold of €335,000 per child. It’s more than back in 2015, when just €675,000 could have been passed on tax-free to three children; however, it’s down by some 38 per cent on 2009.

Do foreigners pay estate tax in the US?

In contrast, non-US domiciliaries are subject to US estate and gift taxation with respect to certain types of US assets, also at a maximum tax rate of 40% but with an exemption of $60,000, which is only available for transfers at death. Obtaining a green card is one way to establish US residency.

How can I avoid paying inheritance tax in Ireland?

Consider depositing €3,000 a year into an account in their name. You can receive a tax free gift from anyone of up to €3,000 every year. This can be a good idea for grandparents to grandchildren. Each grandparent could give €3,000 a year, potentially netting a tax free payment of €12,000 per a year.

Is there a inheritance tax in USA?

Only 1 out of every 700 deaths results in paying the federal estate tax today. The vast majority of estates — 99.9% — do not pay federal estate taxes. While the top estate tax rate is 40%, the average tax rate paid is just 17%.

Can a non resident beneficiary be assessed for Irish tax?

Where the Personal Representative or Executor of the Estate is Irish resident, then that person is obliged to ensure that the Non-Resident Beneficiary discharges the tax and if such Beneficiary fails to do so, the Personal Representative can be personally assessed for the tax.

Do you have to pay US inheritance tax if you live in Ireland?

The double taxation agreement with the US provides that an individual who dies domiciled in any part of the US will only be subject to Irish inheritance tax on their Irish located assets.

Who are the group a beneficiaries in Ireland?

Group A includes beneficiaries who are children of the deceased, including adopted children, step children and certain foster children. The tax free threshold for Group A is €320,000. Group B applies to siblings, nieces and nephews or lineal ancestors of the deceased. There will be no tax applied until the gift exceeds €32,500.

Can a beneficiary in Ireland avoid double taxation?

For other jurisdictions there is no specific double taxation agreement in place so if inheritance taxes arise in Ireland and in the jurisdiction in which the assets are located then the estate/beneficiaries must rely on domestic legislative provisions in order to obtain any relief from double taxation.