Irish Taxation of American Roth IRA Distributions

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Can anyone here confirm for certain that Irish tax residents are not subject to Irish income tax on American Roth IRA distributions? It’s not easy to find dispositive information online.

Roth IRAs are not explicitly mentioned in the Double Taxation Treaty between Ireland and the USA, presumably because it was signed into law in July of 1997 and Roth IRAs were only established in August of 1997. (Similar, but more recent, double tax treaties, such as that between the UK and the USA, do mention Roth IRAs.)

According to Revenue’s website, “Foreign occupational and social security pensions that would not be taxable if the recipient lived in the country that granted the pension” are exempt from tax:

https://www.revenue.ie/en/jobs-and-pensions/pension/private/exempt-pensions.aspx

And Revenue’s Tax and Duty Manual supplies this additional detail:

Section 200 of the Taxes Consolidation Act (TCA) 1997 provides for a tax exemption for certain foreign occupational and social security pensions. Where these pensions are disregarded for income tax purposes in the hands of a resident of the country of source, they are also disregarded for income tax purposes in this State, provided the country of source has a similar income tax system to Ireland.​

https://www.revenue.ie/en/tax-profe...ains-tax-corporation-tax/part-07/07-01-09.pdf

Roth IRAs are not taxable in the US, since they are funded with post-tax earned income, and the U.S. (unlike, say, some countries in the Middle East that do not levy income tax on individual salaries) has an income tax system that is similar to Ireland’s, so it would seem that they should fall under the exemption. But there could conceivably be some question whether they count as occupational pensions, because although only a person with taxable income from (self-)employment can contribute to a Roth IRA, unlike Roth 401(k)s—which must be set up by employers—Roth IRAs can be set up independently by employees (akin to the way PRSAs can in Ireland).

I submitted the following query to Revenue…

According to the Tax and Duty Manual Part 07-01-09, "Section 200 of the Taxes Consolidation Act (TCA) 1997 provides for a tax exemption for certain foreign occupational and social security pensions." The manual states: "Where these pensions are disregarded for income tax purposes in the hands of a resident of the country of source, they are also disregarded for income tax purposes in this State, provided the country of source has a similar income tax system to Ireland." Could you please inform me as to whether U.S. Roth IRAs (individual retirement arrangements)—which are funded with post-tax earned income during employment, and the distributions from which are thus not subject to income tax in the U.S., since the money contributed has been taxed already—fall under this exemption?​

…and received this one-line response: “Based on the information outlined by you the U.S. Roth IRAs fall under the exemption.” I wouldn’t want to make a potentially expensive and irreversible tax-planning decision on the basis of that response alone though, especially given the weasel words “based on the information outlined by you.”

In an article, “The Taxation of Foreign Pensions in Ireland,” published on LIA’s website, Lisa Cantillon corroborates Revenue’s response, writing that, "In practice, [the section 200 TCA 1997] exemption has been seen to operate in Ireland on pension payments from Australia, Switzerland and US Roth IRAs, where payments have been received by Irish residents”:

https://www.lia.ie/resources/news/the-taxation-of-foreign-pensions-in-ireland

Can anyone cite a specific precedent in which Section 200 of the Taxes Consolidation Act (TCA) 1997 has been successfully used to claim an income tax exemption for Roth IRA distributions?
 
In case it's helpful, I recently asked Revenue specifically how distributions from my Roth IRA would be taxed in Ireland and how, if necessary, I should calculate that tax. The response was somewhat more decisive than the one you received.

"You can declare this Income on your annual Income Tax Return under 'Non PAYE Income' under 'Exempt Income'. The following pensions are exempt from tax:
·Foreign Occupational and Social Security Pensions that would not be Taxable if the recipient lived in the Country that granted the Pension

As the Pension would not be Taxable in the USA, it wouldn't be Taxed in Ireland."

Have you found out any more on this topic since August?
 
@Joe Books: It is helpful, thank you! I haven't found out anything more in the meantime, but I may consult with a tax professional to get expert advice, and if I do, I'll update this thread.
 
I find this slightly suprising, since in other contexts I understand that Revenue takes a very narrow view of what amounts to a "pension". On the narrow view, if you have a retirement savings arrangement under which, after attaining a certain age, you control (within limits) how much is drawn out and when, that's not a "pension"; a pension is a series of regular periodic payments, similar to the wage it replaces. So PRSAs and ARFs are not, in the Revenue's view, "pensions" for the purposes of the provisions of the Ireland-Australia Double Taxation Agreement that deal with pensions, for instance, whereas a regular payment from an occupational pension scheme is.

From what's said in this thread, they don't seem to be taking this narrow approach to the pension provisions of the IRL/US DTA. It could be that there's something in the DTA that is inconsistent with that narrow interpretation. Or it could be — less likely, I think — that the Revenue officials dealing with these queries don't appreciate how a Roth IRA works, and in particular don't appreciate that it doesn't provide a "pension" in the narrow sense. Or it could be that this is just an anomaly that, at some point, the Revenue will spot and will correct either by adopting the narrow intrpretation in relation to the US/IRL DTA or by dropping the narrow interpretation elsewhere.
 
@Investor, I'm also seeking advice from cross-border tax professionals and likewise will share back here what I learn.

The first response I recieved was from what appeared to be a generalist Revenue support agent. When I pressed further, gave more detail and asked for specifics, the follow up response was from someone within Revenue specifically in a Pensions department (I'll check exactly what the signature said and update next time I post). Presumably someone in Revenue specializing in pensions should know what they're talking about. But like both of you I'd quite prefer to see something very clearly written and specified in an official format.
 
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