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Hi Alan, My client is getting a gift from her father (US resident) to buy a property in Ireland. The Ireland/US DTA does not deal with gifts therefore only possible relief for double taxation is unilateral relief under s.107 CATCA 2003 For the purposes of that section will funds in US bank account be deemed situated in the US at date of gift even if they are used immediately thereafter to acquire a property here in Ireland? Is there any anti-avoidance legislation on this? Thanks David

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Asked on 16 January 2015 5:07 pm