Irish PRSA and ARF Pension Accounts: IRS Reporting for US Expats

US citizens working in Ireland may participate in Personal Retirement Savings Accounts (PRSAs) or Approved Retirement Funds (ARFs), which are the primary personal pension vehicles in the Irish system. The US-Ireland income tax treaty contains a pension article, but it focuses primarily on relieving double taxation of distributions rather than providing explicit deferral of contributions and earnings during the accumulation phase. For US purposes, employee contributions to an Irish employer pension plan may be deductible if they qualify as a contribution to a "pension plan" under treaty Article 17, but the analysis is not clear-cut for all plan types. Employer contributions to your pension are generally treated as taxable compensation on your US return unless treaty protection applies. Both PRSAs and ARFs must be reported on FBAR and may need to be reported on Form 8938, and because they're personal accounts (not employment pensions), the foreign trust reporting rules may apply as well.