@alainncat , thank you for your answers to my questions. What I get so far is as follows :
(a) You and spouse lived in the USA for a number of years ( assuming that you were not long-term resident rules ), and passed the SPT for the calendar/tax year 2025.
(b) You left the USA during the year 2025 and there for are dual status -- Resident for the period 01/01/2025 till exit date ( say 06/30/2025 for argument's sake ). So you file a 1040 return covering 01/01/2025 till 06/30/2025 and a Non-Resident return on 1040-NR for the period 07/01/2025 till 12/31/2025 and taxed ONLY on US sourced income.
(c) You entered Ireland on 07/01/2025, became a resident for the year 2025 and took advantage of the "Split Year Resident -- and thus your US earnings for the period prior to entering Irish residency is not taxed by Ireland. My reference here is Irish tax manual -- ..>>> Part 34-00-11 - Split year residence- section 822 Taxes Consolidation Act 1997.
Is this what you are trying to achieve --- US taxes only world income till your exit, Ireland taxes only world income thereafter and DTT applicable ONLY for US sourced income ( post exit ) that is taxed by both USA and Ireland?
Or am I in left field ?
