Dual Country Income

D

DrewIreland

Guest
Anyone help me with the following conundrum please?

1. I have an Irish PAYE salary
2. I have US taxaable salary
3. I am Irish resident
4. I received credit in US for certain farm losses in arriving at my "adjusted gross income" (AGI)
5. I paid both Federal and State taxes in US with a higher level of assessable AGI in State.

I assume I am liable/assessable in Ireland as follows:

(a) Irish salary
(b) US salary at the higher AGI level. (The critical point here is that I receive the same effective tax-break in Ireland as I did in US)
(c) Credit in Ireland for both Federal and State taxes paid

Many thanks.
 
Two other issues now occur to me:

i. Is it possible the IS earnings are exempt under Article 15 of the Ire/US Double tax treaty?

ii. If (i) doesnt apply can I claim Foreign earnings deduction relief for 2003 as I spent more than 90 days in US?

Help!
 
It's a pretty technical query requiring a knowledge of cross juristictional tax issues to answer so I would not be surprised if nobody here was able to answer it in which case your only option might be to seek independent, professional advice from somebody with knowledge of both juristictions' tax laws.
 
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