U.S.-listed funds — check the Irish structure
Does it matter which exchange your world tracker is listed on?
If aggregate U.S.-situated assets could exceed US$60,000, compare an Irish-domiciled fund before choosing a U.S.-domiciled equivalent.
Recheck this screen if the IRS threshold or treaty list changes, and calculate it from the investor's aggregate U.S.-situated assets. If that total cannot approach the threshold, fees, liquidity and tax withholding may dominate the choice.
Evidence receipt 4/4 inputs · method v1.6.1
Fixed structural rule; no market score and no ladder shift.
Base policy before today’s readings avoid · Verified structural rule
U.S. corporate stock is U.S.-situated property for a nonresident estate; stock of other corporations is outside U.S. situs under the Form 706-NA instructions.
Limit: This is a product-structure screen, not personal legal advice. The US$60,000 rule is an aggregate filing threshold for U.S.-situated assets; crossing it does not by itself establish tax due. Ownership structures, domicile, deductions, treaties and future law can change the result.
opposes US estate tax filing threshold US$60,000 —
REFERENCE.usEstateThreshold
U.S. corporate stock is U.S.-situated property for a nonresident estate; stock of other corporations is outside U.S. situs under the Form 706-NA instructions.
Limit: This is a product-structure screen, not personal legal advice. The US$60,000 rule is an aggregate filing threshold for U.S.-situated assets; crossing it does not by itself establish tax due. Ownership structures, domicile, deductions, treaties and future law can change the result.
opposes US–Thailand estate tax treaty none —
IRS estate-and-gift treaty list
U.S. corporate stock is U.S.-situated property for a nonresident estate; stock of other corporations is outside U.S. situs under the Form 706-NA instructions.
Limit: This is a product-structure screen, not personal legal advice. The US$60,000 rule is an aggregate filing threshold for U.S.-situated assets; crossing it does not by itself establish tax due. Ownership structures, domicile, deductions, treaties and future law can change the result.
supports Situs of an Irish UCITS holding outside the US —
IRS Form 706-NA instructions
U.S. corporate stock is U.S.-situated property for a nonresident estate; stock of other corporations is outside U.S. situs under the Form 706-NA instructions.
Limit: This is a product-structure screen, not personal legal advice. The US$60,000 rule is an aggregate filing threshold for U.S.-situated assets; crossing it does not by itself establish tax due. Ownership structures, domicile, deductions, treaties and future law can change the result.
neutral Cost of choosing the Irish version roughly 0.04–0.13pp a year —
fund ongoing charges
Subtracting verified ongoing charges is arithmetic; deciding that a particular fee gap is worth a structural benefit is a house judgement.
Limit: The 0.2pp and 0.4pp bands do not include spreads, tracking difference, taxes, platform fees or an individual's holding period.