Ireland as a Destination for U.S. and UK Taxpayers: Tax Considerations

Mr. Warshaw has nearly 40 years of experience as a U. S. estate planning and tax lawyer. He currently represents U. S. and non-U. S. high net worth individuals, families and companies on a wide range of personal and business tax matters, especially in connection with cross-border income and estate tax planning and compliance in the U. S. Mr. Warshaw is admitted to practice in the Commonwealth of Massachusetts. He regularly advises non-U. S. clients on structuring inbound pre-immigration tax strategies including basis step-up in legacy assets, avoiding the U. S. CFC and PFIC anti-deferral tax regimes, optimizing use of foreign tax credits, minimizing green card status as well as advising on and drafting of “drop-off trusts.”  Mr. Warshaw also advises long-term green card holders and U. S. citizens on planning to minimize their U. S. exit tax through gift programs, managing equity compensation and by drafting “expatriation” trusts and considerations of a change of domicile outside the U. S. He has also counseled clients in complying with their U. S. tax filing obligations by engaging accountants and bringing such taxpayers into compliance with their numerous U. S. international tax reporting requirements. Mr. Warshaw has also advised on the U. S. international tax aspects of cryptocurrency, including how to become U. S. tax compliant and how to mitigate U. S. tax implications prior to and following renouncing U. S. citizenship.

Mr. Lesperance is one of the world’s leading international tax and immigration advisors. He has successfully advised scores of high and ultra high net-worth individuals and their families, many of whom continue to seek his counsel today. In addition Mr. Lesperance has provided pro bono advice to many governments on how to improve their Citizenship by Investment, Residence by Investment or “Golden Visa” type programs to better meet the needs of his global clients. He is supported by a team of professionals, some of whom have worked with him since the early 1990s.

Mr. Master acts for some of the Firm's largest private clients and heads our Private Wealth Sector. He acts for high net worth individuals from across the world, but especially from the Middle East, where he acts for many ruling family members and billionaires – many of whose families have US links. Mr. Master's work for these families includes advising on the establishment of global assets holding structures, family governance projects and global real estate investments. He is a Visiting Professor at the University of Law, a Council Member of the International Academy of Estate and Trust Law, and an International Fellow of the American College of Trust and Estate Counsel. Mr. Master's lectures regularly in the UK and internationally on matters of private client interest. He has been featured in eprivateclient’s 50 Most Influential listing, the definitive listing of leading private wealth lawyers, in 2021, 2022 and 2023. Mr. Master's is admitted to practise in England and Wales.

Ms. Richmond is joint Managing Partner and Partner in the Employment & Immigration team advising employers and employees on all aspects of the employment relationship from appointment through to termination. She works closely with HR professionals and management teams advising on day-to-day issues such as disciplinary and grievances, as well as more complex terminations, restructuring and redundancies. Ms. Richmond is an experienced public speaker and delivers seminars to clients and provides tailored training to in-house management teams. With the continued growth in foreign direct investment, and with a large number of international clients, she complements her employment practice by assisting these companies not only with contracts of employment and policies but also providing immigration advice and assistance in relation to work permit applications.

Ms. Dillon is an associate solicitor in the Whitney Moore Employment and Data Protection teams. She joined Whitney Moore as a trainee in 2020 and qualified as a solicitor in 2022. Kate is a graduate of Dublin City University and holds a Bachelor of Civil Law (BCL). Ms. Dillon regularly advises on a broad range of contentious and non-contentious employment matters faced by both employers and employees from at all stages of employment from recruitment to terminations and redundancies. She has represented clients before the WRC in employment disputes and is also experienced in alternative dispute resolution mechanisms such as mediation. Ms. Dillon has experience advising corporate clients in all aspects of data privacy ranging from the organisation’s management of data privacy to the threat of litigation and regulatory investigations. She works closely with clients to ensure compliance with their data privacy obligations by reviewing existing practices within the organisation and working with them towards the implementation of data privacy by design. Ms. Dillon also supports private individual clients on their data privacy and freedom of information rights. She assists private clients in accessing their personal data, advising in relation to data mismanagement and data breaches and, advising in relation to regulatory complaints.

Ms. Miller is a Partner in Warren & Partners with over 20 years’ experience working in taxation and business advisory services. She leads the Private Client and Global Mobility Practice. Ms. Miller has a breadth of practical knowledge in all areas of private client taxation including; tax planning for high-net-worth individuals, global mobility, the Irish remittance basis, share schemes, dealing with Revenue interventions and advising professional Partnerships on a broad range of matters. She graduated from University College Dublin (UCD) with a First Class Bachelor of Science (Industrial Microbiology) degree and went on to acquire a First Class Diploma in Accounting from Dublin City University (DCU). Prior to joining Warren & Partners, Ms. Miller worked as a Senior Manager in the corporate taxation department of PwC for over 7 years advising multinational corporate clients on various matters including M&A transactions. She is a Certified Tax Advisor (CTA) with the Irish Tax Institute (ITI).