L K Williams <lanny[at]loxinfo.co.th> wrote:

- quote -

What if it's a US bank (or an international bank with US
branches) that also has branches in the foreign country? My
guess is that they would be separate corporations, so would
need separate licensing to hold funds in a qualified plan.

Stu

<< ================================================== ===== > << The foregoing is intended for educational purposes only > << and does NOT constitute legal OR professional advice. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2006) - All rights reserved. > << ================================================== ===== >

L K Williams <lanny[at]loxinfo.co.th> wrote:

- quote -

The problem with transferring IRA, 401K, or any other tax
advantaged funds to a foreign country is that the trustee
must be subject to US regulation. This may not be spelled
out in the law, as such, but there are requirements for the
trustees and these include certain record keeping and
reporting issues. Since any foreign bank or financial
institution would not be subject to US law, how would the
IRS be able to enforce these provisions?

Lanny K. Williams, CPA
Nawarat, Williams & Co., Ltd.
Income Tax Services for Expatriate Americans

<< ================================================== ===== > << The foregoing is intended for educational purposes only > << and does NOT constitute legal OR professional advice. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2006) - All rights reserved. > << ================================================== ===== >

Phil Marti <prm20871[at]verizon.net> wrote:
- quote -

Is it possible that qualified pension plans (e.g. 401(a))
are transferrable even if an IRA isn't?

Steve

<< ================================================== ===== > << The foregoing is intended for educational purposes only > << and does NOT constitute legal OR professional advice. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2006) - All rights reserved. > << ================================================== ===== >

L K Williams wrote:

- quote -

So there is no rollover provision.

- quote -

If a person is transferring a foreign tax advantaged
retirement fund into Australia within six months of entering
the country, there is no Australian tax. After six months,
all profits since entering the country are taxable at 15%
within the recipient superannuation fund.

The latest Federal budget has just announced that they are
about to remove all taxes from super fund payments (pension
or lump sum) for fund beneficiaries over 60 years of age.

Thus, if there are no taxes in the foreign country, it would
cost 15% of the gain after entering Australia, then nothing
after that if the fund starts a pension straight away.

UK pension funds can be transferred over to Australian super
funds which meet the UK's new criteria, with no UK taxes.

So you are not aware of any similar rollover regime for
converting a US IRA into a foreign superannuation fund?
I've seen things on Google about IRAs being rolled over to
Canadian RRSPs for people who have left USA permanently,
have you any idea what are they all about?

What would the taxes likely be? I don't know much about the
US tax system.

Travis

<< ================================================== ===== > << The foregoing is intended for educational purposes only > << and does NOT constitute legal OR professional advice. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2006) - All rights reserved. > << ================================================== ===== >

<travismorien[at]yahoo.com> wrote:

- quote -

The only thing I can think of that would have some
provisions is the US/Australia tax treaty. Try IRS
Publication 901

--
Phil Marti
Clarksburg, MD

<< ================================================== ===== > << The foregoing is intended for educational purposes only > << and does NOT constitute legal OR professional advice. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2006) - All rights reserved. > << ================================================== ===== >

travismorien[at]yahoo.com wrote:

- quote -

If the taxpayer is over 70 he should be, or soon should be,
making regular, minimum withdrawals from the IRA. AFAIK, there
are no foreign IRA trustees, so anything transferred to a foreign
bank, etc. will be treated as a total distribution, fully taxable
in the year of transfer. There are no special provisions for IRA
for expatriate taxpayers.

I don't know Australian taxes, so I don't know if it is possible to
put IRA funds into an Australian tax advantaged fund. Even if
possible, it should not affect the fact that the withdrawal will be
fully taxable in the US.

Lanny K. Williams, CPA
Nawarat, Williams & Co., Ltd.
Income Tax Services for Expatriate Americans

<< ================================================== ===== > << The foregoing is intended for educational purposes only > << and does NOT constitute legal OR professional advice. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2006) - All rights reserved. > << ================================================== ===== >

I was wondering if someone could advise on the tax
consequences of transferring funds in an IRA into an
IRA-like foreign fund (an Australian superannuation fund).

I know the taxes at the Australian end, just not the US.

The IRA fund member is over 70 years old and is now a
permanent resident in Australia. He has some other US and
Canadian income in the form of defined benefit pensions and
some social security.

Travis

<< ================================================== ===== > << The foregoing is intended for educational purposes only > << and does NOT constitute legal OR professional advice. > << > << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org. > << Copyright (2006) - All rights reserved. > << ================================================== ===== >