# PRSA transfer to US



## dfg75 (16 May 2007)

Does anyone know the implications of transferring a PRSA account to the US should I decide to retire there? Can this be transferred without incurring additional tax if it moved to a similar US retirement account called an IRA (Individual Retirement Account).

I have spoken to Revenue Pension Division and the Pension Board and cannot seem to get any straight answers. 

Any help would be greatly appreciated!


----------



## boaber (16 May 2007)

Hope this makes sense 


The Occupational Pension Schemes and Personal Retirement Savings Accounts (Overseas Transfer Payments) Regulations 2003 (S.I. 716 of 2003) contain the requirements that must be adhered to prior to an overseas transfer being effected under section 34(2) or 124(2) of the Pensions Acts.  The following is a summary of those requirements: 

1.        The trustees or PRSA provider are required to obtain written confirmation from the trustees, custodians, managers or administrators of the overseas arrangement, to which the transfer is to be made, to the effect that the overseas arrangement provides "relevant benefits" within the meaning of section 770 (1) of the Taxes Consolidation Act, 1997 (see below), and 

2.        The trustees or PRSA provider must be satisfied that the overseas arrangement is approved by an appropriate regulatory authority for the country concerned, and

3.        The trustees or PRSA provider of the Irish arrangement must obtain from the member of the arrangement or the PRSA contributor wishing to make the transfer such information as may be approved by the Pensions Board. 
While the Pensions Board has not to date approved any information in respect of paragraph 3 above, this does not deprive the Regulations of their effect.


"relevant benefits" means any pension, lump sum, gratuity or other like benefit—

(a) given or to be given on retirement or on death or in anticipation of retirement or, in connection with past service, after retirement or death, or

(b) to be given on or in anticipation of or in connection with any change in the nature of the service of the employee in question,
but does not include any benefit which is to be afforded solely by reason of the death or disability of a person resulting from an accident arising out of or in the course of his or her office or employment and for no other reason;


----------



## F. Kruger (16 May 2007)

dfg75

Were you thinking in terms of transferring the fund or having your pension(from Annuity or ARF) paid to you in the US?


----------



## dfg75 (16 May 2007)

I would transfer the assets of the PRSA into an equivalent retirement account in the US. I would essentially be looking to liquidate the assests and tranfer them to an American retirement fund with Fidelity or similar. I do not believe I could avail of the same funds that I currently have with New Ireland in the US with a brokerage firm like Fidelity. Furthermore, the managment fees appear to be much lower in the US on mutual funds, ETF's etc.

From speaking with the Internal Revenue Service (equivalent of Revenue)in the US, the money would have to be done through a direct transfer of all assests to American brokerage company to avoid paying income tax on those funds. What I am trying to avoid is having to pay taxes on the money in Ireland as well, since the money will be staying in a retirement account which is not accessible until after age 65.


----------



## dfg75 (17 May 2007)

boaber said:


> Hope this makes sense
> 
> 
> The Occupational Pension Schemes and Personal Retirement Savings Accounts (Overseas Transfer Payments) Regulations 2003 (S.I. 716 of 2003) contain the requirements that must be adhered to prior to an overseas transfer being effected under section 34(2) or 124(2) of the Pensions Acts. The following is a summary of those requirements:
> ...


 
Thanks. Would I be correct to assume that it is up to the the PRSA provider to determine whether the overseas transfer account (in this case Rollover IRA) is a suitable retirement account? I have attached links to the IRS website for descriptions of various retirement plans (401k and IRA) for your reference to determine whether these would be deemed suitable transfer accounts.

http://www.irs.gov/taxtopics/tc451.html
http://www.irs.gov/taxtopics/tc424.html
http://www.irs.gov/pub/irs-pdf/p590.pdf

If it is the transfer possibility is to be determined by the PRSA provider, would I also need to make contact with Revenue when the transfer was to take place?

Thanks again for you help!


----------



## boaber (17 May 2007)

You should provide as much detail to NI as possible, it will be up to them to determine whether the overseas transfer account (in this case Rollover IRA) is a suitable retirement account.

Note: you will have to have a policy set up in the US that the PRSA can transfer into - NI will require policy number etc.. before they can transfer the funds out of the PRSA - assuming they agree to the transfer.

This is a direct quote from an email from the Retirement Benefits District of the Revenue Commissioners:  "Note it is up to trustee/administrators to satisfy themselves that all requirements at met. It is not up to Revenue to approve individual cases."

So in answer to your last question, I don't believe the Revenue need to be contacted.


----------



## dfg75 (17 May 2007)

Boaber

Thanks a million for your help!


----------



## AnnSmith (13 Jun 2008)

Hi.
I am in a similar situation.  I am an American working in Ireland.  I would like to transfer my pension to the US system when I move back.  However, according to my pension manager, there are 'no suitable' US options to accept the Irish pension.
I can't be the first person to want to transfer an Irish pension to the US, but you'd think no one had done it before.
If you have any suggestions on specific US pension programs that I could transfer my Irish pension, I would be most appreciative.
Thank you.


----------



## Guest117 (13 Jun 2008)

IMO the dollar will get weaker before it gets stronger so for what it is worth consider that before you transfer funds


----------



## shaking (13 Jun 2008)

You can't transfer pension benefits to the US currently pensions can only be transferred between ireland and the UK


----------



## boaber (13 Jun 2008)

shaking said:


> currently pensions can only be transferred between ireland and the UK



*This is not the case at all!!*

I refer to [broken link removed] of the Revenue Pension Manual. 

Part 13.4 states 





> Transfers to the U.K. should be dealt with on exactly the same basis as transfers to E.U. Member States. Please refer to 13.6 below.



Part 13.6 states 





> If the transfer is to another EU Member State, the overseas scheme must be operated or managed by an Institution for Occupational Retirement Provision ( IORPS), within the meaning of the EU
> Pensions Directive, and must be established in a Member State of the European Communities which has implemented the Directive in its national law. The scheme administrator must be resident in a EU Member State.
> If the transfer is to a country outside the EU, a transfer may not be made to a country other than the one in which the member is currently employed.


----------



## shaking (16 Jun 2008)

apologies I stand corrected!!


----------



## Don_08 (16 Jun 2008)

As far as I know - you cannot transfer to the US - definitely not a 401k and nearly sure not to an IRA.  The problem lies in the fact that you can draw down before retirement age in these schemes and take them all as cash.  That does not correspond with the reason the Revenue provide tax relief on contributions.

There are a lot of other countries you can transfer to  - Oz and a number of European countries - but not the US.


----------



## charibdis (23 Jun 2008)

Hi There, first time poster, i got to this thread by doing a search on "transfer my irish pension to the US."  I'm in a similar situation, have 10 years worth of Irish pension built up and will be moving to the US this fall following the death of my father last year.  I have an old US pension and 401k fund, and want to move my Irish funds over but Mercer says this cannot be done.  Has anyone else found a way to complete such a transfer?  Would it be possible to take out only the portion of the fund I paid in myself, minus the employer contribution, and minus any back taxes owed?  There must be a way to do this..

Any thoughts or further comments would be greatly appreciated.

Thanks & Regards


----------



## Don_08 (23 Jun 2008)

Really is no way to do so.  But when your pension comes into payment you will be able to get it paid to the US - thats the only solution.  Leave it in Ireland until retirement age and sort it out then.


----------

