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Adding US and Irish work records to maximise my pension

Q&A: Bilateral arrangements govern pension rights for work done outside EU countries

Bilateral agreements are in place with countries such as the United States covering areas like pensions

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Dominic Coyle
Tue Oct 5 2021 - 05:00

Regarding your recent article – Making Sense of the New Way of Qualifying for a State Pension – prior to emigrating to the United States in 1985, I worked in Ireland for five years. This month, I will be 65 years old. I plan to work for the next 16 months, at this point I will have maximised my social security.

My question is can the contributions that I made during my five years that I worked in Ireland be added to my social security contributions here in the United States?

I am aware that Ireland/Canada have a bilateral agreement with regard to this. I have been unsuccessful in getting a firm yes or no from the different agencies that I have reached out to both here and in Ireland.

Mr P.O’H., United States

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You are not alone. Thousands of people have moved between the United States and Ireland for work over their careers. For some, this was as a result of career progression within the extensive network for US companies operating in Ireland or the growing number of Irish multinationals with a presence in the US. For others, it was simply a case of emigrating to the US in search of a better future and for still others a case of relocating to Ireland.

In most of these cases, people will have a work record in both countries – and possibly others.

Outside the EU, Ireland has a series of bilateral arrangements with countries governing social insurance. As you say, this includes Canada. It also includes the United States, Australia, New Zealand, South Korea and Japan. Because they have a different social security system to the rest of Canada, Ireland has a separate bilateral agreement with Quebec.

It also has bilateral agreements with Austria and Switzerland, though both are superseded by the EU rules. The same is true for the UK, even after Brexit. So the large number with mixed work records between here and Britain or across the northern Border will have their eligibility assessed under EU rules.

Each of these agreements has their own separate rules. These are quite precise and I would advise anyone finding themselves in the position to check with local agencies for full clarity. Knowing where to go, as you have found out, can be half the problem.

Bilateral agreement

The Irish bilateral with the US dates back to 1993. I am looking at a explainer of the agreement published by the US Social Security Administration, dated 2017.

If you were based in Ireland at this stage, you would apply to the Department of Social Protection and they would work out your entitlement in much the same way as within the EU – i.e. they use the formula A x B / C, where A is the notional rate of Irish pension you would get if all your stamps in both countries were treated as Irish, B is the actual number of stamps accrued in Ireland and C is the total number of social insurance contributions across both countries.

The difference is that, within the EU, the total is the cumulative number of contributions worked across all EU states. In relation to bilaterals, where you have worked in more than one of the countries covered by such agreements the ratio is worked out with each country you have worked in independently.

Ultimately for any Irish state pension, only the result giving you the largest Irish pension is relevant from the Irish side.

It will then apply for you for a pro rata pension from the other country. While, the Irish pension is determined by only one bilateral, you may be entitled to pensions from more than one other country depending on your social insurance record in each.

As with the EU rules, for the bilateral regime to come into force you must have a certain number of social insurance stamps. In the case of Ireland, that is one insurable week in employment and 52 “reckonable” weeks – i.e. worked or credited. Over in the US, that is generally six quarterly earned credits, so 18 months of work.

US resident

Now, looking at the agreement from a US resident perspective, where you are, it says specifically that you cannot use your Irish work record to increase your US pension where your US social security record will already qualify you for a benefit. In your case, where you will have maxed out your social security by 2024, this is clearly the case, so you cannot simply add the Irish contributions to the US record.

The agreement says that,where you do not have enough work credits under the US system to qualify for regular benefits, US authorities will look at your work record in both countries to see if you can qualify for a partial benefit.

But, even if you cannot boost your pension from the US authorities, it is still possible as far as I can see to secure a pro rata pension from the Irish authorities in respect of those five years of work over here before you headed for the US.

The agreement does say that, if you did not need to agreement to qualify for social security benefits in either country, the amount of your US benefit could be reduced. However, in this case, you would need the agreement to qualify for the Irish benefit so, to my reading of it, you should be okay.

It won’t be much financially, but there’s no reason not to pursue it.

According to the documents I am looking at, as you live in the US, you can apply by visiting or writing to any US social security office. There is also a freephone number 1-800-772-1213.

It says you can apply for Irish benefits by completing an application form SSA-2490, which should be available at any social security office.

If you live in Ireland and wish to apply for benefits under the bilateral agreement with the US, or another country, contact the Department of Social Protection (Pensions Section) in College Road, Sligo or by phone at 071 915-7100 or (for the price of a local call) 1890-500-000. The 1890 numbers are being phased out from January, so that lo-call number prefix will change to either 0818 or 1800 next year.

Please send your queries to Dominic Coyle, Q&A, The Irish Times, 24-28 Tara Street, Dublin 2, or email dcoyle@irishtimes.com. This column is a reader service and is not intended to replace professional advice. No personal correspondence will be entered into

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