Dividend on US shares held in the US

ctlsleh

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I work for a US company and have RSUs that i pay oncome tax on in ireland when they vest. the reality is that the value of the stock has declined so if i were to sell it is would have made a capital loss compared to the value that they vested at (and consequently the value that I paid tax against). The RSUs are held in an account in the US (etrade) however the company, as many companies in the US are doing now due to tax changes, are paying a special divident this year. so i will get about $10K in dividend payed into that US account.
What i would like to understand is if this dividend is taxable in the US or in Ireland? if in ireland is it CGT or income tax, im assumgin income tax and is it possible to offset that against CGT losses in other shares etc?

thanks for any advice, im trying to minimise the tax payable on this dividend, i welcome any replies.
 
Are you resident and domiciled in Ireland. Dividends are subject to income tax PRSI and USC. capital losses are not offsetable against dividends. The dividends are subject to 15% withholding tax in the US and then marginal rates in ireland with a credit for the US tax.
 
Thanks Joe90.......yes, i am domiciled in ireland.....I assume it is a self declared tax return?

So effectively I loose 52% off the value having already paid 52% on the vested value of the shares which are now worth less than 50% off the value at which they vested. So basically if I were to sell the shares I wouldn't even recover the tax I paid on them.....so nett zero income....but I still have to pay 52% on the dividend......!

Wow......!! Not a good deal......!
 
You're deriving an income of $10k from the shares, so it's taxable as income accordingly.

If you sell the shares you'll realise a CGT loss which you can use to reduce CGT gains, or carry forward indefinitely against future gains.

If you've paid 52% taxes on the vested value, it means you got the shares for free (or if you take the taxes as the cost, for 52% of face value), so I'm not sure what your problem is - you surely didn't have to take up your share rights? - in which case you'd have no risk, but you wouldn't be getting a 10k dividend and the possibility of future increase in value...
 
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