Brendan Smith (Cavan-Monaghan, Fianna Fail)
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68. To ask the Minister for Finance if his attention has been drawn to the concerns of Irish citizens that were born in the United States of America but came to live in Ireland at a very young age and that have retained their US citizenship and are now classed as accidental Americans (details supplied); and if he will make a statement on the matter. [49958/18]

Paschal Donohoe (Dublin Central, Fine Gael)
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The issue which that the Deputy has raised refers to Irish resident individuals who are US citizens but do not have economic links with the US. These individuals are subject to US tax on the basis of having US citizenship. The phrase “accidental Americans” has been used to refer to these individuals.

Ireland signed an Intergovernmental Agreement with the United States in December 2012 to implement the US Foreign Account Tax Compliance Act (FATCA). This Agreement provides for a bilateral, and reciprocal, exchange of information with the US. The information exchanged includes information in relation to financial accounts held in Irish Financial Institutions by US citizens.

Part of the information Irish Financial Institutions are required to report to Revenue, for transmission to the US, is the US Tax Identification Number (TIN) of the US account holder and an Irish Financial Institution is obliged to obtain a TIN from a US account holder. As “accidental Americans” were born in the US and are US citizens subject to US tax, the relevant information – including a US TIN – in relation to their accounts must be reported to Revenue under FATCA.

The issue of "accidental Americans", and how the US tax system impacts on such US citizens who are not resident in the US, has been brought to the attention of the US authorities at EU level.