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expat777(Newbie)Newbie
31 Aug 2025

AU status: PR

Other citizenships: USA

Retirement accounts in question: Roth IRA & Roth 401(k)


I'm advised that if I retire while in Australia and activate my USA retirement accounts, they will be taxed as a foreign trust with rates similar to income tax (rather than CGT, etc).


(1) If I move back to USA, does AU take any cut of the assets when I move or stop being an AU resident for tax purposes?


(2) If I retire while in the USA and not an AU resident for tax purposes, will AU take taxes on the payments from the USA retirement accounts?


(3) After the USA retirement accounts are empty, if I later return to AU, will there be AU taxes on the money related to the USA retirement accounts at that time?


(4) Do the answers to questions 1-3 change at all if I become an AU citizen instead of PR?


Thank you.

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804 views
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knaresbro(Devotee)Devotee
1 Sept 2025

As you're no doubt aware, there's a fundamental difference between the tax systems of Australia and the USA. The former, like all but two countries in the world, has residence-based taxation ... and the latter is unfortunately one of the two that has citizen-based taxation!


Luckily, the answer to all three questions - given you will not be an Australian resident for tax purposes at the time - is "no"; ATO taxes won't apply. (And "if I become an AU citizen instead of PR?" isn't going to make a difference.)


You should, however, consider what taxes would apply in Australia if you're here at the time of a withdrawal. Whilst income from Roth accounts (which is generated from after-tax contributions) is tax free in the USA to US taxpayers, the ATO doesn't quite differentiate between a 401(k) and a Roth 401(k) in the say way. So you may pay some tax, calculated only on the fund's earnings and generally not on the contributions.


And lastly (from my family's experience) I'd suggest you find a dually-qualified tax specialist and/or do lots of research from reputable sources. And I wish you the best of luck, @expat777 !

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