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Irish Non-Dom Investing in a US Operating Company

Jmeery1

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Sep 30, 2019
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Hi all

I'm a non-dom living in Ireland (so only pay tax on income brought to Ireland).

There's a good opportunity to buy into a stake in a US operating company (a C-Corp). It would be a big stake (ie more than 20%)

Does anyone know the best way to hold shares in a US Company?

My main concern is capitsl gains tax.

Im confused because if a non-resident alien sells shares in a US company on the NYSE or NASDAQ, it is not Effectively Connected Income in the US and there is no capital gains tax.

If I am a passive shareholder in a private US company though, it seems that it IS Effectively Connected Income.

Has anyone had any experience with this?

Thanks for any help!