Welcome to Tax Bites for Expats, the top tax tips you

want to know as an expat. The podcast is here to help answer

the common queries and concerns expats have when moving to or

from Ireland. Complex taxes explained simply.

We'll focus on the Irish and international tax issues to be aware

of to ensure you save time, money and stress.

Hi everyone, Podcast producer Matt here stepping in for Steph in the

Furious approach to the tax assessment deadline here in Ireland. Make

sure you're on top of it too. This episode is Part one

with Sean Carney of Amvoy Wealth. Sean is an

expert financial planner helping Irish expats in the US to plan for their

future and avoid the pitfalls of the tricky US Tax system and what

Irish citizens commonly ignore regarding managing US

Finances. In this episode we hear about Sean's

background in financial, how he has helped people already in his

business, and the first few major tips. For those of you considering moving to the

US or back to Ireland, make sure you're subscribed so that

you don't miss part two and check the show notes for more details.

Enjoy.

Hi everyone, welcome to this episode of Tax Bites for Expats.

Today we are going to speak with Sean Carney of Amvoy

wealth. Anvoy wealth is a cross border financial planning firm

that have offices in Dublin and New York and they specialize in

assisting Irish citizens who are classed as US Connected

individuals, that is Irish citizens who are moving to or living

in or returning from the us. It also includes people who

have US based assets or those who are connected to the US by green

card, passport or birth and we know from experience

that includes many many of our listeners. Sean's going to talk to us

today about some of the issues his clients encounter and how he helps

them solve cross border financial planning problems. He was

born in the US to Irish parents and has lived in Ireland since the age

of two, but he currently lives in Manhattan and he has dual Irish and

US citizenship, so he understands firsthand the issues that his

clients face. He's also regulated to transact investment

business in both Ireland and the us meaning he's regulated by the Central bank of

Ireland and the Security and Exchange Commission in the us.

And before I introduce him, he has also offered a free

introduction call to anyone who quotes tax bytes for Expats

podcast if they listen to this episode and reach out and contact

him. And his contact details are going to be in the show notes. So without

further ado. Sean, thank you for joining us. Welcome to the

podcast. Stephanie. Thank you so much. It's an absolute pleasure to be here.

I'm an avid listener, so, like everything, you always know when you

hit the pinnacle of things, when you appear on things. Been watching.

You're very kind. Well, look, thank you. Yeah, it's very

delighted to have you. You're a rare breed of financial planner and it's great to

have you on the show. Before we get into some of the detail that might

be of interest in terms of what you do, tell us a little

bit about yourself and I suppose a little bit about Envoy wealth

and how it came to be. Yeah, well, I've been in the

financial services, I guess, industry. I'd hesitate to call it financial planning when

I started, but I'm in the financial services industry since

2000. That's a lot of years now at this stage. Nearly

25 years. Got into it in the early days working with Irish life. And it's

pretty much a sales job. A lot about targets and selling and how we

could, you know, get people to take out pensions, savings and

investments, stabilize life for a number of years. Great training, set up my

own. And about 2006 and kind of

been on my own. Joined up with a few different people along the way, which

has been great. But 2011, I guess, was really a

changing point in my career in that not only were

we in the middle of a financial crisis, but the certified financial planner

qualification came to Ireland. I was one of the first people to go through that

process, and I guess it made me look totally differently about

what we were doing. Turned from a sales job to a,

I guess ultimately a coaching job where you're sitting down with clients and you're trying

to help them to understand what it is that life looks like and

then how money impacts their life. So, yeah, qualified in that

2020, I was getting a little bit, I guess, bored

with financial planning in Ireland. You know, there's a lot of people doing. A lot

of people doing the same thing. I had started to realize that there

was an issue with Irish people in Ireland at the time.

People coming home from America that had U.S. assets. They didn't know what to do

with them. Me, as a financial planner in Ireland, didn't know what to

do with them, you know, and I think that's a common theme across Ireland with

financial planners, similarly here in the US So when you go

to a financial planner or financial advisor in Ireland or in the us

all they want is really to talk about and all they understand

is your Irish stuff or your US stuff. But there is

a huge Impact on cross border assets. Certainly, you know,

we've discussed it, you know, particularly from a taxation perspective. So it's

something I started to look at, realized there was quite a niche over here.

The main people, I guess that deal with these cross border issues

over here and in Ireland seem to be the. Advisory

firms, the accountancy firms. The problem with them is

they deal with the high end of high net worth individuals.

So there's a whole level of people kind of below these

that are getting no advice. And it goes back to that old

adage. The biggest issue that we have is that we don't know what we don't

know. So for the majority of these people, me included at the time,

as a US citizen, I didn't understand fully the

impact of being required to do a tax return to the

IRS on an annual basis. So I started to look at what

that would look like. I had no idea to ask about it because nobody was

doing what it is that I wanted to do. So I undertook probably the

craziest thing that I've ever done that I just want to set up

an advisor firm in the US and get it registered with the

SEC and that I would run that in tandem with the Irish firm that I

had running with the Central Bank. Four years down the line, a lot

has changed. I would love to have known four years ago, well, I know now

because I'd have done a lot of things differently, but it's been an

unbelievable journey, it really has. And I guess it's culminated with

18 months ago I moved here to New York, living in Manhattan.

I'm living the dream. Ideally I'd love to be 20 years younger over here.

It's an amazing city for lots of reasons. You know,

pace to get up and go about people, you know, if business is

what you're looking for, this is where you come. I'd love to have the energy

of a 25 year old to put into what I have. But yeah, I'm

making a goal but now and I really love what I. Do over here and

I'm sure, Blake, yeah, that takes bravery. And I know you said, you know, you

look back and think, oh, I wish I'd known. But that's part of the journey,

isn't it? You learn as you go. And it's not a path that's very well

trodden because we would often hear clients say to us when they come and they

ask tax questions, well, who can I speak to about the cross

border financial issues? And the short answer is there isn't that many

People that I'm aware of who are operating in the space that

you're in. So congrats for carving out a very successful

niche. Tell us about the people that you've worked

with to date. How do they find you and why do they come to work

with you? Yeah, I guess the main people that I'm concentrating on now,

what I have the Irish business and I have the US business. The US business

is my core business at the minute and it's what I'm really trying to concentrate

on and grow. You know, the Irish diaspora, the Irish network over here. You

have two very different, I guess, nationalities walk

and living side by side. The US people absolutely love

themselves. I love that about them. The most confident, the most

brash, the loudest people you're ever going to meet are the people that you see

in New Yorkers. The problem is they walk across you to get

to their destination. Both physically and metaphorically. The

Irish people are a lot kind of closer. They've all

traveled a fairly similar path. They've all come over here to a strange company away

from home and they've all, I guess, had to

start from scratch and build something from there. And even the likes

of people that have come into, you know, tech and into the

pharma and into the, you know, the bigger construction companies over here, it's

all starting again when you come over here. So the Irish diaspora over

here is very close. The network is brilliant. And that's what I've

started, I guess I've started to look at and I've had some great help

from various different networking groups over here. And Irish people,

thing about the Irish people over here is they love to help you and they

genuinely mean it. The Americans genuinely mean

they'll help you so long as they can get something out of you and would

probably take whatever you were looking for off you. And I don't mean that in

a bad way. That's just the way it is over here. The Irish people are

genuinely here to help. So I've used a lot of that and

started to build up a really good network around that. I guess what I found

is, which is what I thought I knew before I came over,

is there is no alternative. There really isn't. I am

sitting here. You talk about a needle in a haystack. You know, there

are thousands of Irish US

connected people with assets in Ireland or assets in Ireland than the

US who are thinking about moving home or thinking about moving over

and they're not getting proper advice. And actually, you know what, as

you Say that it makes me think when we left Australia,

I'm not going to pretend one of the top things on my list was what

do I do with my Australian pension, my super. It was just one of the

things I was. Okay, I'll think about that afterwards. Talk to us about

why that might be more of a problem for some of your clients because of

their connection with the us I suppose from an Aussie perspective, it's not as big

a deal, but tell me why or tell people who don't understand why. Is that

a problem to potentially do that? Look, I guess people are leaving the us.

Irish people are funny. And again, it may sound like, I mean down on Irish

people. I was born in America, but I consider myself Irish. I love

Ireland. I love it over here, but I don't think I'll be over here forever.

And so when I talk about things that I feel that Irish people do

wrong, you know, it's to try and get them to understand that and

try and get them to do something about it. People come over here to America,

they build up assets over here and they move back home and they

assume that it's just another bank account or it's just another investment account

that they have in the US and that's the way they consider because again, they

don't know any better. They don't understand the implications. The

reality is, particularly if you're green carded or if you're a citizen

over here, there are issues around, I guess, taxation and

requirements that you need to do on an annual basis. The reality

is if you move back home and you are green carded or you

are a US tax citizen or a citizen, you need

to do a tax return on an annual basis. So just

going home and parking stuff can have huge

implications down the road if the IRS come knocking on the

door. It's funny, I think we've discussed this before. One of the

main places people get their financial information

when they're moving from one country to another is online. And I don't mean

Google, which is bad enough, but you see people asking questions

on Facebook that they have no business really asking on Facebook. They should be

asking people that understand fully. So, again, look, you've

probably seen it. There's Facebook groups out there and they're brilliant, they really

are, for raising awareness of what needs to be done.

But somewhere like that is not going. Just because somebody did

something with a 401k before they left the US to go back

to Ireland doesn't mean A, it was the right thing and B, it certainly doesn't

mean that they're qualified to give you advice. Totally. And you

know, even from a tax perspective, we talk about the surely category,

but surely this is the answer. And you know, usually that advice has been given

to somebody from their friend, very well meaning friend. And that's not to say it's

wrong, but it's also not to say it's right. So your point is very

valid. And I think, you know, what people don't see and what we see

more of probably as advisors is I suppose, the

sophistication around the ability for different

governments, particularly the US to share information and gather

information from other institutions globally. To your point, I think

you're spot on. A bury your head in the sand approach might

be okay, but it isn't wise. And it also might not be okay

forever. Proactively speaking, you know, somebody listens to that and

think, oh, do I have a problem? What does working with you

look like? Because obviously there's, you know, the aspect of let's do this right.

What is, what's the overall aim that you want someone to achieve when they

come to you? Yeah, I guess I can over here, going

back to the whole circle. Financial planner and I use cash flow

forecasting software when I deal with clients. You know, when I was in Ireland, it

was very simple. You sat down with a client and they were able to say

to you, you know what, it's 47 years of age, I work here, here's my

assets, here's my expenditure, here's my liabilities. Plan me

out for the rest of my life. And that's very simple to do because we

can use cash flow forecasting. It's never going to create a plan that's exactly spot

on. We use assumptions in it, but it allows us to get as close as

we possibly can to what your future cash flows are going to look like. A

lot of people I meet over here, one of the questions they're asking is because

everyone that comes to the US from Ireland genuinely believes

they're going home. Not, maybe not everyone, majority of people genuinely

believe they're going home. The future, the reality is that life gets in the

way. And if life doesn't get in the way, they just stop thinking about

it. And days run into months, run into years, run into decades, and the next

thing you're 50 or 60 and you still haven't got home. The main reason I

find people don't go home is because they don't think about it or they don't

plan to go home. So I guess from my perspective, when somebody comes to

me here, the very first thing that I like to do or that I think

they should do is to try and understand what the next 5, 10, 15,

20 years are going to. You know, my process, you know, when people

come to me, they get a little bit confused because I

don't start talking about money, I don't start talking about investments. I don't

start talking about, you know, give me your 100,000, I'd invest that.

And we get this time, 10 years, we'd have 57

million in a bank account. You'd be rich. For me, it's about trying to understand

what does your future look like? What do you want it to look like? That

makes perfect sense because ultimately these are people who

are in the middle of making a big life decision. Yeah. So therefore, you know,

the questions relating to what you want, it's not necessarily, oh, I'm coming to you

because I want extra turn. They're coming to you because they're about to do something

in their life that is a big deal. I think your questions are very sound,

very astute. I know, absolutely. But people tend not to think about that

way because to them there's two things, my life and my

money. And the two of them go hand in hand. They absolutely go hand in

hand. But unless you understand what your life is looks like or what your life

wants to look like, then the money doesn't really matter.

Because if you have a pot of a million or you have a pot of

20 million, if you don't understand what you need that money to do in the

future, then you have no real idea of how you can spend it. So

when clients come to me, if I can get them to understand, you know, okay,

I'm here, I'm going to stay here for five years and then I want to

look at going home to Ireland. We can plan out five years here and then

we can plan the exit. The exit is the important piece. You know, planning in

Ireland and planning in the US are pretty much the same. Planning

is a universal thing. Okay. Where I want to live, where I want

to work, how many kids I want to have, what age my kids, what am

I spending my money on, what do I want to drive, where do we want

to go? All these things are universal. What you want to do in America is

probably similar to what you want to do in Australia, what you want to do

in Ireland. It's, it's understanding what that is and then

layering the money back in and trying to understand, well, you know, if we have

X pot of money, how does that change or how does

that fund what we want to do on this side? But the key

piece that they need to look at is if they want to go home, what

do we need to do? And I guess the tax piece is, there's no

question of all of this. The tax piece is the most important piece

because it's the piece they can either make or break their plan even though they

don't understand it. Because if they don't look after that piece property, they could

have a knock on the door in 5, 10, 15, 20,

50 years time from the IRS going, you didn't do

something 50 years ago. And you know what we're going to do? We're

not going to take the money you had 50 years ago and look at that,

we're now going to look at the money you have now 50 years later, which

could be considerably more. And that's what we're going to start drilling down into. That's

what we're going to start taxing on. They're the bits, I guess, that people need

to. So I think I'm incredibly important in people's

lives and in people's process. And what does it force me to admit somebody

else is if somebody came to me and they said, I've only time to talk

to one person, you or somebody else, I would send them to you

for that pure and simple reason that that bit is actually more important because that's

the piece they could explode their life. Simple things. And he asked me earlier,

I guess I've spoken around in circles about, you know, when people are leaving

the U.S. what do they need to be taken in mind? If you're not green

carded or you're not a citizen, it's not

as big a deal. But for people particularly green carded, and these are the people

that I kind of see that don't look much into it because what they do

is they come over here and the first thing they want to do is get

a green card. It's an Irish thing because it goes back years, probably goes back

to the 80s when green card was considered the golden ticket. Get a green

card, you could get out of an Ireland that had no money, you could go

to the US and you could make a life for yourself. And New

York is, you know, it's living proof of that. The amount of people I'm meeting

over here that came over here in the 80s that have made huge money,

have done incredibly well for themselves in reality stuff, they wouldn't have done

at home and that's fine. These people are probably here for life. But you have

people that come over and go, I want a green card. The implications of having

a green card are quite considerable. And you know, you

absolutely shouldn't get a green card just because you think you want

one. You need to sit down. There are great

immigration attorneys over here that you should sit down with. Some of them will

allow a 15, 20 minutes initial meeting for free.

Anything you can get for free in the US is amazing. But you know, have

these meetings to understand the implications because a lot of people

will come over here, get a green card and then leave. If you leave under

certain situations, that is time with the green card, a lot of people

go, I'll just go home and keep my green card and say nothing because it'll

go out of date. An hour date green card is the same as an out

of date passport. You're still considered to have a green card, but you

have none of the benefits. You can't travel back in and out of the country,

but what the IRS can do is they can still tax you

and you should still be doing a tax return. So part of an exit

process of a green card is, is that you sit down,

you explain that you're leaving the country, they will assess you

financially and if you hit certain thresholds, you may have

to pay tax on assets and investments. As people, we go,

no, I'm not doing that because I don't want to pay tax. I think you'll

agree one of the things that you should do before you leave the US with

investments is rebase them and pay any taxes due on them

because CGT is lower up here than it is. Again,

these are the reasons that people should always vote you for this simple.

Things just as well. Just to kind of not out one point

that you said there that that may be an assumption if someone's listening

to that. In that example you just gave of somebody having

potentially to pay a tax to the US on exit for whatever reason.

There is no credit mechanism in the Irish US treaty for that.

So I suppose what we have there is very, very

solid example of when this does go wrong. And I have seen

it go wrong once in practice, thankfully only once. And it

went fairly badly wrong for the person two people in question. But

the point is this can have fairly bad outcomes from a tax

perspective. And the very simple thing is this. It probably was very

easily avoided because it is about. You say this

constantly. Plan in advance. Plan in advance also as

well. Just in this conversation, one Thing that you said that struck me,

that we see quite frequently is like we're talking here about green

card holders, but what about the fact that maybe they've married a US citizen on

the way out or if they're coming back, do you know what I mean? So

my point is, you know, so do you work with that

cohort? So let's say you've got an Irish person who went over, they had a

green card, they hand it back or they don't, whatever, they've gotten married to a

US citizen and they as a cohort are coming back to Ireland. Do you service

them as a married couple? Let's say, yeah. No. And again,

the more complex you can make yourself, and I don't mean that in a bad

way, an Irish person getting married to a US citizen is,

it's not an issue in real life, it's an issue from a tax

perspective, from an estate planning perspective. All these things end up

becoming an issue. Now, as you said, not a big issue because they can easily

be sorted. They become an issue if you don't sort them out before

you leave or after you leave and start to do the stuff that you're

obliged to do, legally obliged to do. Because the last thing you want is

the IRS to come knocking on your door down the road. And the IRS don't

mess around. I didn't know or I forgot

or nobody told me that. It's probably not something that's going to

make the IRS go out. If you didn't know, then we don't care. They don't

mess around. And the reality is they have the power, to the best of my

knowledge, and you can't correct me on this if I'm wrong to go into your

IR's bank account and pretty much take money out of your Irish bank account, you

woe to them. I can't verify that, but I would believe it.

The powers that tax authorities have are probably

often more far reaching than we would like to believe.

And I think the point I would make is in terms of, I

suppose, cross border reporting and you know, things like FATCA and the

common reporting standard that we see, these are all basically acronyms for

processes that are in place to allow financial institutions

on an international level to share information with governments and

tax authorities. So you know, sometimes people will say to us, well, nobody will

know if I don't say it. And somebody said to me once, I really like

the analogy, it's like, well, yeah, you know, you could step

out on the road and you might not get hit by a bus. But I'm

not going to tell you to look, step on the road without looking in case

it happens. So the point is, it's. We're talking about self assessment here. You

know, your obligation is to declare and

you'll be penalized if you don't. That's what we're saying. So

be proactive. It's never an issue until it becomes an issue. And that is the

piece. And it's simple. I guess the issue that I have, and it's a similar

issue that you have, is that there's not enough of you or

me. And in general, Irish people particularly are terrified

of competition. I would love if there was more of me for

the pure and simple reason that there's more clients that I'll ever be able

to service over here on varying different

levels. And I have to prioritize, therefore I have to charge

fees. Some people won't pay fees and this again, not beating the

Irish people. But the Irish people in general

hate paying for any fees. To them, they

will genuinely value something

that's perceived as free, particularly in this

industry, a free financial review. No problem doing

that. I'm going to charge you a fee. And it's going, hey, hold on a

minute. I'm not sure I want to do that. You know, the

fees that people will pay, certainly you and me,

is far less than the penalties down the road for not doing or not

doing property. I go further than that and I say

that you can pay a fee and save money or you can not

pay a fee and pay money like that usually works out like that. Usually it's

very, very rare, very rare that a client doesn't recoup the cost of the. So

view it as an investment. And I think, you know, financial planning,

investment, these are people who have investments, they understand the concept of

investing well. If they're not willing to invest in something simply because it doesn't

come with, you know, an asset and a brokerage statement, perhaps the disconnect is there

between the right client and your service. But I would

imagine if anybody listens to the

complexity of trying to understand how

to offer advice that you offer across border, perhaps then they would

understand why a cost comes with a fee. Tell me, answer this question for me

because this is a question that's not easily answered. Clients

will very often say to me, and I don't need you to give all your

trade secrets away. Clients will very often say to me, oh, you know, leaving the

US my investment account

manager or my kind of service provider, they want me to update my address.

And I've put in that I'm now living in Ireland and they've come back and

told me that I can't invest with them anymore. What do you say to somebody

who said that to you? Because we hear that a lot. Yeah, yeah. Now

again, there's one company out there in particular that if you tell them

that you are no longer going to be resident in the U.S. particularly if you're

going back to Ireland, they will write you a check for your account. Not that

simple, but they'll send it straight out. And this includes

401ks. You tell this company that you're moving back to Ireland.

Retirement accounts here in the US are done slightly different than retirement

accounts in Ireland in that if you take funds from a

life company in Ireland, cash in a pension area, the life company will

deduct tax from it. Over here, you get the gross number out. So if you

have a million euros in a 401k and the investment company

doesn't want you investing with them anymore because they're moving back to Ireland, they will

send you paycheck for the full value of your fund

and the onus will be on you to pay the tax on that. Now, some

of us are very cute Irish people. We think we get away with paying no

tax and that and we go home and we cash it or we forget to

put the pay the tax on it. But again, I'm not

saying you will be, but you could be caught up. And if you are caught

up, you'll probably lose the whole million euros or

million dollars. And possibly then. So

that is an important piece. What would you say to that person?

Okay, so that example, somebody says, I've come back. Let's say they come

back with a million. I can't imagine there's. Oh, well, you should do this.

It's a process, isn't it? It's, it's the sitting down, it's the figuring

out. I mean, obviously they probably don't want a million in cash. Yeah, it

totally is. Just. Sorry. And I guess just two things on that. What do I

advise people to do? If you have a US address,

you'll need a US correspondence address for the majority

of investment houses to allow you to continue to invest with it. So again,

something to look into. I'm often asked the question, do I leave my money in

the US or do I bring it home? And I guess that's not a

simple yes, no, it's not a one size fits all. That's where

the planning piece comes in do you ever intend going back? What do

you need this money for? There is a piece of advice and I

have advised people to withdraw their 401k before they go

home, pay the tax on it, the simple thing, and going back to again, you

know, what payout will they get in exchange for paying their

fees, say to the likes of you? If somebody comes to you and says they

have a million euros in a brokerage account, I've sat it, sat there for the

last 10 years or whatever. I started off with 500,000,

so my growth, 500,000, you know, their CGT to be paid

on that. The rate of CGT in the US is considerably

lower than the rate of CGT back in Ireland, usually

between 15. To 18% depending on which is a. Lot of

half a million. It's a lot of growth, isn't it, to give away. Yeah.

So from your perspective, I assume one of the first piece of advice you'd be

given them is rebase that, pay. Your cgt and also just one

point there. Right. So they're not just rebasing the growth in the asset, they're

actually, and this gets a bit complex, but it's important, it's worth mentioning. They're also

effectively rebasing for better or for worse, because obviously it depends the

FX movement over that period. Because the Irish capital gains

tax is calculated with reference to spot foreign exchange rates which have moved

over time. So we could see, you know, a U.S. gain on

paper of like $100. But when you convert that to euro using the

appropriate exchange rates, it can potentially augment again. The point

being this can save, you know, a lot of money if when you

compound the tax with whatever the foreign exchange conversion

throws up, people often don't appreciate that point until the calculations shown

to them and look at what this actually is. But yeah, that's a very simple

thing to do and you know, the timing, the appropriateness of

it. This is then when really what we're looking

at is somebody in the middle to kind of coach

people about the right decisions, be able to offer them investment

solutions. Because just be really clear here, not everyone can

do this and offer investment solutions. And then a US advisor and an Irish

advisor from a tax perspective who both speak to each other like, we've seen

that, haven't we? Where when that happens, it works really, really well.

And people, what do they get? I mean they get confidence, they

get clarity and they save a lot of money. Who doesn't want

that? That's perfect financial planning.

Thanks for listening to tax bites for expats, Please do leave a

rating or review wherever you listen to your podcast. And as always,

remember to take professional tax advice specific to your

personal circumstances before acting or refraining from action

in connection with the matters dealt with in this series. The material

in this podcast is intended to give general guidance only.