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Irish Will for US Citizens with Dual-Country Assets — Guide

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Guide only — nothing on this page is for sale. Irish Will for US Citizens with Dual-Country Assets: how it works in Ireland, when you need a solicitor and how to find one through the Law Society of Ireland’s Find a Solicitor directory.

SKU: OLS-US-WILL-2026 Categories: ,
Operated by Plus Promotions Limited (not a solicitor’s practice)
OnlineLegalServices.ie is operated by Plus Promotions Limited, which is not a solicitor’s practice and does not give legal advice. Documents sold here are self-complete templates and the guides are general information only. If your matter needs a solicitor, use the Law Society of Ireland’s Find a Solicitor directory.

Information only — not sold online

Read the guide below, then instruct a regulated Irish solicitor. Our self-complete templates can help you prepare before you do.

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This matter needs a solicitor. Under Irish law this work must be carried out by a solicitor, so it is not sold on this site. This page is a guide to what is involved. OnlineLegalServices.ie is operated by Plus Promotions Limited, which is not a solicitor’s practice and does not give legal advice. To instruct a regulated practice, use the Law Society of Ireland’s Find a Solicitor directory.
Quality assurance — Templates are prepared for use in Ireland and updated when the law changes. OnlineLegalServices.ie is operated by Plus Promotions Limited, which is not a solicitor’s practice and does not give legal advice. If you have any concerns about your template, contact us and we will put it right or refund you.

Information only — this matter needs a solicitor. OnlineLegalServices.ie is operated by Plus Promotions Limited, which is not a solicitor’s practice and does not give legal advice, prepare documents or take on cases. This page is a general guide and nothing on it is for sale.

To instruct a solicitor, use the Law Society of Ireland’s Find a Solicitor directory.

Work of this kind is carried out by a solicitor regulated by the Law Society of Ireland. We are not a solicitor’s practice and do not provide it — to instruct a solicitor, use the Law Society of Ireland’s Find a Solicitor directory. Protect your family, your 401(k), your IRA, your US real estate and your Irish assets with one coordinated Will under Irish law.

Why US citizens in Ireland need a dedicated Will

If you die intestate in Ireland, your estate is distributed under Part VI of the Succession Act 1965 — not according to your wishes and not necessarily in a way that minimises US estate-tax exposure. If your US assets are covered only by a US Will, the Grant of Probate process in Ireland can drag on for 12 to 18 months while the two jurisdictions are reconciled. A properly drafted Irish Will, coordinated with your US estate plan, solves both problems.

What this service covers

  • Full Irish Will drafted under the Succession Act 1965, compatible with an existing or planned US Will.
  • Cross-border asset schedule: 401(k), IRA, Roth IRA, US bank accounts, US real estate, US brokerage accounts, Irish PRSA / PRB, Irish bank and property.
  • Legal right share analysis for your spouse (Section 111 of the Succession Act) and alignment with US spousal-election rules.
  • Guidance on the US-Ireland Double Taxation Convention (1949) and the US-Ireland Estate Tax Treaty interaction.
  • Beneficiary designation review — because 401(k)s, IRAs and life insurance pass outside the Will and can accidentally override it.
  • Executor and guardian appointments, including a section on whether your US executor can act in Ireland (most cannot without an Irish professional co-executor).
  • Clear witnessing instructions so your Will is validly executed under Irish law (Section 78).
  • One round of revisions after you review the first draft.

Who this is for

  • US citizens recently moved to Ireland on a Stamp 1G, Stamp 4 or Stamp 0 visa.
  • Dual US-Irish citizens who have split their lives between the two countries.
  • Green-card holders returning to Ireland who still hold US assets.
  • US retirees on the Stamp 0 income-based residency programme.
  • Remote workers employed by a US company but now tax-resident in Ireland.

How it works

  1. Instruct a solicitor of your choice. Pay the in EUR or USD equivalent via secure Stripe checkout.
  2. Complete the cross-border instructions form. A structured questionnaire covering both Irish and US assets, tax domicile, spouse and dependents.
  3. First draft by email. Delivered via secure link for your review.
  4. Revision round. One full set of amendments included.
  5. Signed-ready Will. Sent with step-by-step witnessing instructions for execution anywhere in Ireland.

Frequently Asked Questions

Do I still need a US Will if I have an Irish Will?

Usually yes. US real estate and US-situs assets are generally best handled by a US Will to avoid US probate complications. An Irish solicitor can coordinate with your US attorney so the two Wills do not contradict each other. If you do not have a US attorney, we can introduce you to a US-qualified partner firm.

What about my 401(k) and IRA?

These typically pass by beneficiary designation, outside either Will. Part of this service is an explicit beneficiary-designation review so you don’t accidentally leave them to an ex-spouse or an estate that then pays unnecessary US estate tax.

Am I exposed to US estate tax on my Irish assets?

US citizens are taxed on worldwide estates, including Irish property, subject to the lifetime exemption (currently in the millions of US dollars). The US-Ireland Estate Tax Treaty provides credits to avoid double taxation. We flag the interaction; your US attorney or accountant handles the US filing.

Can I sign my Will remotely?

Under current Irish law the Will must be signed in the physical presence of two independent adult witnesses. This can be done anywhere in Ireland. We provide detailed step-by-step instructions.

What if I have children who are US citizens born in Ireland?

Your Will should address both guardianship (Irish law) and trust structures (often US law) so that inheritance tax and US gift-tax rules do not trigger accidentally. We cover this in a dedicated section of the Will and the pre-signing call.

How long does the whole process take?

From payment to signed-ready Will is typically 2 to 3 weeks, depending on how quickly you complete the instructions form and respond to the first draft.

Trusted by US families in Ireland

the guidance notes team regularly drafts Irish Wills for US citizens across Dublin, Cork, Galway and every other county.Payments are processed by Stripe; we never store your card details. Instructions are submitted over HTTPS and stored on GDPR-compliant EU infrastructure.

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If you would like to be told when solicitor services are available again on this site, you can join our no-fee waiting list. To instruct a solicitor now, use the Law Society of Ireland’s Find a Solicitor directory.

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OnlineLegalServices.ie is operated by Plus Promotions Limited (CRO 670635).
Plus Promotions Limited is not a solicitor’s practice and is not regulated by the Law Society of Ireland or the Legal Services Regulatory Authority. We publish legal information and sell self-complete document templates. We do not give legal advice and do not prepare documents for you. Where your matter needs a solicitor, instruct a regulated practice through the Law Society of Ireland’s Find a Solicitor directory. About this site and regulation · Solicitors: work with us

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OnlineLegalServices.ie is operated by Plus Promotions Limited (CRO 670635), which is not a solicitor’s practice and is not regulated by the Law Society of Ireland. Documents are self-complete templates and general information, not legal advice.