New Zealand taxation of US retirement accounts?
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New Zealand taxation of US retirement accounts?
I am a US citizen who is married a Kiwi (with New Zealand citizenship). I've accumulated a decent nest egg for my retirement ~$800K ($500K trad, $300K roth). Given a few life changes, we expect that we'll move to NZ in a few years, very possibly not moving back to the US for a long time even in retirement.
I feel as if I made a mistake by putting money in my 401K. It looks like when I move to New Zealand, after my first four exemption years, I will start to be taxed by NZ on withdrawals from my 401K (treated as foreign superannuation), and there is no tax treaty between US and NZ on these retirement accounts, which means I would be taxed once by US and once more by NZ when I am retired and withdrawing money. For reference, I am 47 now, so if I do an early withdrawal during my four exemption years, I would still get the a 10% penalty.
Is there advice for people who leave the US and face potential double-taxation? I grew up learning that I should always save for retirement in 401k's and IRAs, but I am learning that wasn't very sound advice as the world is more globalized. Should I have saved for retirement in my taxable accounts if I knew I was going to end up leaving the US?
I feel as if I made a mistake by putting money in my 401K. It looks like when I move to New Zealand, after my first four exemption years, I will start to be taxed by NZ on withdrawals from my 401K (treated as foreign superannuation), and there is no tax treaty between US and NZ on these retirement accounts, which means I would be taxed once by US and once more by NZ when I am retired and withdrawing money. For reference, I am 47 now, so if I do an early withdrawal during my four exemption years, I would still get the a 10% penalty.
Is there advice for people who leave the US and face potential double-taxation? I grew up learning that I should always save for retirement in 401k's and IRAs, but I am learning that wasn't very sound advice as the world is more globalized. Should I have saved for retirement in my taxable accounts if I knew I was going to end up leaving the US?
Last edited by Stereo1687 on Fri Jun 02, 2023 3:33 pm, edited 1 time in total.
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Re: Made a mistake saving so much in 401k's?
I wouldn't be so hard on yourself. None of us can predict the future. Perhaps you never met your partner, or things didn't work out and New Zealand was never an option. You did the best you could with the information you had available at the time. New Zealand is beautiful, enjoy your time there!
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Re: Made a mistake saving so much in 401k's?
If you knew, then it was a mistake. Otherwise, no.
Re: Made a mistake saving so much in 401k's?
Does NZ treat money in Roth IRAs the same way? If treatment of Roth IRAs is more favorable, then you could roll at least the Roth portion of the 401k out to a Roth IRA.
I believe - but am not 100% certain so hopefully someone else can chime in - that if you roll the Roth portion of the 401k over to a Roth IRA, then you'd get around the 10% penalty on the amount you contributed (but not growth).Stereo1687 wrote: ↑Wed May 31, 2023 4:56 pm For reference, I am 47 now, so if I do an early withdrawal during my four exemption years, I would still get the a 10% penalty.
Re: Made a mistake saving so much in 401k's?
Is the 401k for a former or current employer? If former, perhaps convert it to a Roth IRA before leaving.
Re: Made a mistake saving so much in 401k's?
Let's be clear on terminology here, since OP mentioned that the 401k is a mix of traditional and Roth. Are you recommending a rollover, conversion, or both?
Re: Made a mistake saving so much in 401k's?
The only thing worse than paying taxes on money you've made is not making that money in the first place.
Re: Made a mistake saving so much in 401k's?
Roth IRA is viewed as an investment account and the gains are subject to taxes (FIF). There are a number of tax protections for foreign superannuations that will avoid most of any double taxation, although I could not quickly find a definitive answer for the US.
Re: Made a mistake saving so much in 401k's?
The OP has not given us enough information to address that. If he is no longer an employee, then yes I’d to a rollover for the traditional part (or maybe including the Roth). Then once rolled over a Roth conversion. You may be able to do both in one step now.
If he is an active employee with the 401k, I guess do that before he moves.
If he is going to keep working for the same company in NZ, then I don’t know. I’d talk to the company HR to see what options may be available.
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Re: Made a mistake saving so much in 401k's?
Odd that there isn’t a clause in the tax treaty for retirement monies. Maybe you will get lucky and they will update/revise the tax treaty in the next 13 (?) years. I agree with the other posters that this wasn’t a “mistake”, it’s just life. It is another line item on the list of pro/cons one makes when one is faced with these choices.
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Re: Made a mistake saving so much in 401k's?
What about Roth conversions? If you convert to Roth under US tax law then does NZ tax Roth principal as well or just the growth? You could also try converting now to Roth and withdrawing the entire principal (no age limit) or at least as much as you can, you have to wait 5 years from conversion to withdraw but you can start a conversion ladder right away.
Last edited by stocknoob4111 on Wed May 31, 2023 6:22 pm, edited 1 time in total.
Re: Made a mistake saving so much in 401k's?
The gains from when? From the very beginning? I’m not sure that all investors even track their Roth basis so how would NZ tax retroactive gains?sailaway wrote: ↑Wed May 31, 2023 6:12 pmRoth IRA is viewed as an investment account and the gains are subject to taxes (FIF). There are a number of tax protections for foreign superannuations that will avoid most of any double taxation, although I could not quickly find a definitive answer for the US.
I guess once converted to Roth IRA you could pull out the contributions, and as much of the gains that you can before moving.
Re: Made a mistake saving so much in 401k's?
Both Traditional and Roth IRA’s can be subject to tax in New Zealand upon withdrawal. The amount of tax owing to the IRD on a US retirement fund withdrawal can also depend on how long you’ve lived in New Zealand, which is calculated over a 30 year period.
"I started with nothing and I still have most of it left."
Re: Made a mistake saving so much in 401k's?
If Roth is taxed too perhaps it is best to pull some out to taxable.
- make sure OP already has Roth set up for 5 year rule of earnings withdrawal
- roll 401k and Roth out of 401k to traditonal and existing Roth IRA
- convert Traditional IRA to Roth. Move into existing Roth IRA
- pull out Roth contributions to taxable account
- pull out earning from Roth account after 5 year rule passed - within the 7 years from now (3 before move and 4 years after)
- make sure OP already has Roth set up for 5 year rule of earnings withdrawal
- roll 401k and Roth out of 401k to traditonal and existing Roth IRA
- convert Traditional IRA to Roth. Move into existing Roth IRA
- pull out Roth contributions to taxable account
- pull out earning from Roth account after 5 year rule passed - within the 7 years from now (3 before move and 4 years after)
Re: Made a mistake saving so much in 401k's?
Is there an ax on your neck (and timeframe) to relo to NZ !? It’s your choice on location and timing of such future move - and you pay consequences.
What if someone contributed 401k in highly taxed state (let’s say, they saved near 10% state taxes on contributions), and then moved to Zero/low taxes state in retirement. Do you say, they got lucky, or planned well !? Or, if you did opposite (zero tax state to fully taxed state during withdrawals) - do we consider you made unwise move !? Such is life ..
Besides - neither you, nor anyone else clarified Roth withdrawals weren’t protected from NZ taxation.
Let us ask you - retroactively, what would possibly been great move (or the lack of!)
What if someone contributed 401k in highly taxed state (let’s say, they saved near 10% state taxes on contributions), and then moved to Zero/low taxes state in retirement. Do you say, they got lucky, or planned well !? Or, if you did opposite (zero tax state to fully taxed state during withdrawals) - do we consider you made unwise move !? Such is life ..
Besides - neither you, nor anyone else clarified Roth withdrawals weren’t protected from NZ taxation.
Let us ask you - retroactively, what would possibly been great move (or the lack of!)
Re: Made a mistake saving so much in 401k's?
From the time you become a resident. This is basically a wealth tax that applies to brokerage as well as Roth accounts. This is a separate issue from the 401k being considered a foreign super.JBTX wrote: ↑Wed May 31, 2023 6:20 pmThe gains from when? From the very beginning? I’m not sure that all investors even track their Roth basis so how would NZ tax retroactive gains?sailaway wrote: ↑Wed May 31, 2023 6:12 pmRoth IRA is viewed as an investment account and the gains are subject to taxes (FIF). There are a number of tax protections for foreign superannuations that will avoid most of any double taxation, although I could not quickly find a definitive answer for the US.
I guess once converted to Roth IRA you could pull out the contributions, and as much of the gains that you can before moving.
Re: Made a mistake saving so much in 401k's?
There are many people, myself included, who would happily pay double tax to have the opportunity to permanently move to New Zealand. Enjoy it!
Re: Made a mistake saving so much in 401k's?
I don't understand. New Zealand foreign superannuation https://www.ird.govt.nz/income-tax/inco ... rannuation mentioned double tax agreements, following the link gives one between US and NZ. If the 401k is from pretaxed money, then all withdrawals are taxable, does this tax treaty not applicable and not being double taxed?
Re: Made a mistake saving so much in 401k's?
Does NZ allow a foreign tax credit? If the US and NZ tax the same income (such as a 401(k) withdrawal), can you take a NZ tax credit for the US tax paid on the same income? This is the way most countries avoid double taxation when there is no tax treaty exemption. It looks like there is a Dual Tax Agreement between US and NZ, but I didn't look into the details.
It does work this way for US residents in the US. You will see a lot of discussions on this forum about the foreign tax credit; if you hold a US-based stock fund holding foreign stocks, foreign countries tax the dividends, and you get a US tax credit for the tax paid to those foreign countries. (But the tax has to be on the same income; if the US taxes dividends on a foreign country's equivalent to an IRA, there is no tax credit because the foreign country is not taxing those dividends.)
It does work this way for US residents in the US. You will see a lot of discussions on this forum about the foreign tax credit; if you hold a US-based stock fund holding foreign stocks, foreign countries tax the dividends, and you get a US tax credit for the tax paid to those foreign countries. (But the tax has to be on the same income; if the US taxes dividends on a foreign country's equivalent to an IRA, there is no tax credit because the foreign country is not taxing those dividends.)
Re: Made a mistake saving so much in 401k's?
A key thing I would be to get professional tax advice since this is way beyond a DIY situation or something suggestions on the internet can help you figure out.Stereo1687 wrote: ↑Wed May 31, 2023 4:56 pm Is there advice for people who leave the US and face potential double-taxation?
Something you might ask your tax advisor about if you might be able to return to the US periodically to get out of the double taxation situation. For example if you spent six months in some place in the US that might allow you to do Roth conversions.
Not only do you need to figure out the tax situation with 401k withdrawals but you should also have good estate planning since if you die before your husband then he could be in a complicated tax situation if he inherits your retirement accounts. As a non-resident alien his estate could also be subject to ridiculously high estate taxes if he still has accounts in the in the US when he dies.
Be sure to also ask your tax advisor to look at what you need to do to not be subject to state income taxes in your old state. The rules are not intuitive and doing something like leaving stuff in a storage unit in the US can show an intent to return to the state.
Also keep in mind that the tax brackets are schedule to revert to the old higher rates in 2026 if there are no tax law changes by then so some thinks may be less expensive to do before then.
There are hardship exemptions where you do not need to pay that 10% penalty so you might see if you could qualify for one of those.Stereo1687 wrote: ↑Wed May 31, 2023 4:56 pm For reference, I am 47 now, so if I do an early withdrawal during my four exemption years, I would still get the a 10% penalty.
https://www.irs.gov/retirement-plans/pl ... tributions
I am not familiar with them but interesting buying a house can be a qualifying event but there are all sorts of restrictions. It seems unlikely but if you are lucky and going to buy a house in NZ then that might allow you to do a hardship withdrawal in some situations before you are in the double taxation situation. You would still need to pay taxes on it, likely in a high tax bracket so that might not be worthwhile even if you could do it.
Re: Made a mistake saving so much in 401k's?
short answer:
Article 22 of USA, New Zealand tax treaty explicitly avoids the double taxation. Further they define 401k's are treated as pension funds and explicitly lay out how these are taxed and avoid the secondary taxation.
https://www.irs.gov/pub/irs-trty/newzld.pdf
Long answer:
OP, you need to understand a few things how these work. USA has tax treaties with a number of countries and NZ is one of them. This is the order of favorability:
1) Sometimes these tax treaties address retirement accounts explicitly and provide the exact tax rate agreed between countries.
2) If they missed/skipped it, they will address who gets to tax based on origin source of income and thereby address if other country would skip taxation by type of income. (401k's usually fall under retirement/pension funds).
3) If they skipped the above part, there is a section on double taxation avoidance agreement. Usually this will lead to highest tax rates between the two countries that will get split into a certain way between both countries. Source country taxes first. If the tax rate of destination country is higher they collect the difference.
4) If all the above are not part of agreement, most countries have foreign tax credits for taxes paid to other countries.
5) Finally, if the residing country does not have a foreign tax credit, this is the usually the worse case that you are worrying in original post.
Now, I am not an expert on NZ but having read through USA-UK, USA-France and USA-India treaties for our wiki, I can assure you New Zealand is at least in step 2/3 above.
Now from my brief read, items of interest:
Article 18 section 2,(this was from 1980's when 401k are still not popular)
If you choose SEPP from 401k, in the past tax courts have sided with the interpretation of pension. In short, if you use SEPP, only USA can tax this but I haven't went through everything to say this has been negated somewhere.
article 22, section 2 talks above how double taxation is avoid and calculation are done in regard to income from different sources.
Article 13, may be of interest if you have property in USA.
Further in 2008, USA and New Zealand reached an amended agreement, in which they defined:
https://home.treasury.gov/system/files/ ... 6-2009.pdf
Note: The above data is from my first read and please do not take it as settled matter.
Article 22 of USA, New Zealand tax treaty explicitly avoids the double taxation. Further they define 401k's are treated as pension funds and explicitly lay out how these are taxed and avoid the secondary taxation.
https://www.irs.gov/pub/irs-trty/newzld.pdf
Long answer:
OP, you need to understand a few things how these work. USA has tax treaties with a number of countries and NZ is one of them. This is the order of favorability:
1) Sometimes these tax treaties address retirement accounts explicitly and provide the exact tax rate agreed between countries.
2) If they missed/skipped it, they will address who gets to tax based on origin source of income and thereby address if other country would skip taxation by type of income. (401k's usually fall under retirement/pension funds).
3) If they skipped the above part, there is a section on double taxation avoidance agreement. Usually this will lead to highest tax rates between the two countries that will get split into a certain way between both countries. Source country taxes first. If the tax rate of destination country is higher they collect the difference.
4) If all the above are not part of agreement, most countries have foreign tax credits for taxes paid to other countries.
5) Finally, if the residing country does not have a foreign tax credit, this is the usually the worse case that you are worrying in original post.
Now, I am not an expert on NZ but having read through USA-UK, USA-France and USA-India treaties for our wiki, I can assure you New Zealand is at least in step 2/3 above.
Now from my brief read, items of interest:
Article 18 section 2,(this was from 1980's when 401k are still not popular)
Code: Select all
2. Annuities derived and beneficially owned by a resident of a Contracting State shall be
taxable only in that State. The term "annuities" as used in this paragraph means stated sums (not
being alimony) paid periodically at stated times during life or during a specified or ascertainable
number of years, under an obligation to make the payments in return for adequate and full
consideration (other than services rendered or to be rendered)
article 22, section 2 talks above how double taxation is avoid and calculation are done in regard to income from different sources.
Article 13, may be of interest if you have property in USA.
Further in 2008, USA and New Zealand reached an amended agreement, in which they defined:
https://home.treasury.gov/system/files/ ... 6-2009.pdf
Hope this helps you as a starting point.For application of the Convention by the United States, the term “pension fund” includes
the following: a trust providing pension or retirement benefits under a Code section 401(a)
qualified pension plan, profit sharing or stock bonus plan, a Code section 403(a) qualified
annuity plan, a Code section 403(b) plan, a trust that is an individual retirement account under
Code section 408, a Roth individual retirement account under Code section 408A, or a simple
retirement account under Code section 408(p), a trust providing pension or retirement benefits
under a simplified employee pension plan under Code section 408(k), a trust described in section
457(g) providing pension or retirement benefits under a Code section 457(b) plan, and the Thrift
Savings Fund (section 7701(j)). Section 401(k) plans and group trusts described in Rev. Rul. 81-
100, 1981-1 C.B. 326, and meeting the conditions of Rev. Rul. 2004-67, 2204-2 C.B. 28, qualify
as pension funds to the extent they are covered by Code section 401(a) plans and other pension
funds.
Note: The above data is from my first read and please do not take it as settled matter.
When in doubt, http://www.bogleheads.org/forum/viewtopic.php?f=1&t=79939
Re: Made a mistake saving so much in 401k's?
great response - if one you, as non-NZ aspirant, gathered this much data., first Kudos to you. Secondly, it sounds like OPs grievance about 401k, or ever having to pay tax on it (worse yet, pay any prepayment penalty on early withdrawals) - than working/understanding tax-treaties.ray.james wrote: ↑Wed May 31, 2023 11:58 pm short answer:
Article 22 of USA, New Zealand tax treaty explicitly avoids the double taxation. Further they define 401k's are treated as pension funds and explicitly lay out how these are taxed and avoid the secondary taxation.
https://www.irs.gov/pub/irs-trty/newzld.pdf
Long answer:
OP, you need to understand a few things how these work. USA has tax treaties with a number of countries and NZ is one of them. This is the order of favorability:
1) Sometimes these tax treaties address retirement accounts explicitly and provide the exact tax rate agreed between countries.
2) If they missed/skipped it, they will address who gets to tax based on origin source of income and thereby address if other country would skip taxation by type of income. (401k's usually fall under retirement/pension funds).
3) If they skipped the above part, there is a section on double taxation avoidance agreement. Usually this will lead to highest tax rates between the two countries that will get split into a certain way between both countries. Source country taxes first. If the tax rate of destination country is higher they collect the difference.
4) If all the above are not part of agreement, most countries have foreign tax credits for taxes paid to other countries.
5) Finally, if the residing country does not have a foreign tax credit, this is the usually the worse case that you are worrying in original post.
Now, I am not an expert on NZ but having read through USA-UK, USA-France and USA-India treaties for our wiki, I can assure you New Zealand is at least in step 2/3 above.
Now from my brief read, items of interest:
Article 18 section 2,(this was from 1980's when 401k are still not popular)
If you choose SEPP from 401k, in the past tax courts have sided with the interpretation of pension. In short, if you use SEPP, only USA can tax this but I haven't went through everything to say this has been negated somewhere.Code: Select all
2. Annuities derived and beneficially owned by a resident of a Contracting State shall be taxable only in that State. The term "annuities" as used in this paragraph means stated sums (not being alimony) paid periodically at stated times during life or during a specified or ascertainable number of years, under an obligation to make the payments in return for adequate and full consideration (other than services rendered or to be rendered)
article 22, section 2 talks above how double taxation is avoid and calculation are done in regard to income from different sources.
Article 13, may be of interest if you have property in USA.
Further in 2008, USA and New Zealand reached an amended agreement, in which they defined:
https://home.treasury.gov/system/files/ ... 6-2009.pdf
Hope this helps you as a starting point.For application of the Convention by the United States, the term “pension fund” includes
the following: a trust providing pension or retirement benefits under a Code section 401(a)
qualified pension plan, profit sharing or stock bonus plan, a Code section 403(a) qualified
annuity plan, a Code section 403(b) plan, a trust that is an individual retirement account under
Code section 408, a Roth individual retirement account under Code section 408A, or a simple
retirement account under Code section 408(p), a trust providing pension or retirement benefits
under a simplified employee pension plan under Code section 408(k), a trust described in section
457(g) providing pension or retirement benefits under a Code section 457(b) plan, and the Thrift
Savings Fund (section 7701(j)). Section 401(k) plans and group trusts described in Rev. Rul. 81-
100, 1981-1 C.B. 326, and meeting the conditions of Rev. Rul. 2004-67, 2204-2 C.B. 28, qualify
as pension funds to the extent they are covered by Code section 401(a) plans and other pension
funds.
Note: The above data is from my first read and please do not take it as settled matter.
But bigger concern would be how his/her Roth be Nz taxed on withdrawals - but betcha, it would not catch as
many eyeballs- so, we may never see that thread ..
Re: Made a mistake saving so much in 401k's?
I would first edit the thread title in the first post to attract those who know both US and NZ taxation. I’m guessing some comments already made haven’t taken the differences into account.
Maybe OP wants to title the thread something like:
New Zealand vs US Retrement Accounts -or-
New Zealand Taxation Ideas -or-
USA to New Zealand Financial Changes.
Maybe OP wants to title the thread something like:
New Zealand vs US Retrement Accounts -or-
New Zealand Taxation Ideas -or-
USA to New Zealand Financial Changes.
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Re: Made a mistake saving so much in 401k's?
Thanks all for the help & insights. To explain my situation, when I leave the US I will be leaving my current employer, which means I can rollover into my IRAs. It sounds like that is preferred in case I want to withdraw my contributions
I am really struggling with understanding the tax treaty. It'd be amazing even if I just have to pay the higher of the two countriestax rates, but when I read online posts, it seems to contradict the ray.james' interpretation. Here are two blogs I'm looking at:
https://www.usglobaltax.com/article-us- ... or-expats/
https://www.nzustax.com/nz-tax-treatmen ... -accounts/
I think there are at least two things I'd like to confirm if you experts have any thoughts :
- it looks like I would be for sure taxed by NZ on my Roth IRA withdrawals?
- for my pretax IRAs, it sounds like I can claim a credit when filing by NZ tax return right?
I know this is really arcane & niche, so I'm super grateful for everyone's insights already. If no one knows or has any thoughts that's totally fine - I already appreciate all the effort put in.
I am really struggling with understanding the tax treaty. It'd be amazing even if I just have to pay the higher of the two countriestax rates, but when I read online posts, it seems to contradict the ray.james' interpretation. Here are two blogs I'm looking at:
https://www.usglobaltax.com/article-us- ... or-expats/
https://www.nzustax.com/nz-tax-treatmen ... -accounts/
I think there are at least two things I'd like to confirm if you experts have any thoughts :
- it looks like I would be for sure taxed by NZ on my Roth IRA withdrawals?
- for my pretax IRAs, it sounds like I can claim a credit when filing by NZ tax return right?
I know this is really arcane & niche, so I'm super grateful for everyone's insights already. If no one knows or has any thoughts that's totally fine - I already appreciate all the effort put in.
Re: New Zealand taxation of US retirement accounts?
I am under the assumption that almost all countries tax 401k and IRAs like this. I believe there are only a small handful of countries who do not. btw, the US also taxes foreigners retirement accounts if they move here. For some reason, they have not done tax treaties on these sorts of accounts. So don't beat yourself up - it's commonplace and much broader than just NZ.Stereo1687 wrote: ↑Wed May 31, 2023 4:56 pm I am a US citizen who is married a Kiwi (with New Zealand citizenship). I've accumulated a decent nest egg for my retirement ~$800K ($500K trad, $300K roth). Given a few life changes, we expect that we'll move to NZ in a few years, very possibly not moving back to the US for a long time even in retirement.
I feel as if I made a mistake by putting money in my 401K. It looks like when I move to New Zealand, after my first four exemption years, I will start to be taxed by NZ on withdrawals from my 401K (treated as foreign superannuation), and there is no tax treaty between US and NZ on these retirement accounts, which means I would be taxed once by US and once more by NZ when I am retired and withdrawing money. For reference, I am 47 now, so if I do an early withdrawal during my four exemption years, I would still get the a 10% penalty.
Is there advice for people who leave the US and face potential double-taxation? I grew up learning that I should always save for retirement in 401k's and IRAs, but I am learning that wasn't very sound advice as the world is more globalized. Should I have saved for retirement in my taxable accounts if I knew I was going to end up leaving the US?
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Re: Made a mistake saving so much in 401k's?
Treaty Article 18 reserves primary taxing rights to NZ (state of residence), but the US eviscerates much of the treaty for US citizens (lucky you!) with its spiteful 'saving clause', Article 1 paragraph 3, which allows it to tax US citizens as if the treaty had not come into effect. What you will end up with on normal pre-tax 401k and IRA withdrawals then is NZ tax first, and then US tax on top but only to the extent that your US tax is at a higher rate than NZ. You finesse this using treaty Article 22, by claiming a US tax credit against NZ tax you paid. Form 1116 has a special 'income resourced by treaty' category just for this case.Stereo1687 wrote: ↑Fri Jun 02, 2023 3:32 pm I am really struggling with understanding the tax treaty. It'd be amazing even if I just have to pay the higher of the two countriestax rates, but when I read online posts, it seems to contradict the ray.james' interpretation. Here are two blogs I'm looking at:
https://www.usglobaltax.com/article-us- ... or-expats/
https://www.nzustax.com/nz-tax-treatmen ... -accounts/
Roths (post-tax) get no mention in the treaty. Unless there's special NZ tax law on these, one possible (most likely?) outcome is that NZ will treat them as if a vanilla unwrapped trading account. That means annual tax on gains inside the account (dividends, realised gains), but no particular additional tax on withdrawals. So at minimum you could probably reset your basis in these accounts by a sell-repurchase jut before becoming NZ resident. Perhaps also skew these accounts towards tax-efficient (low dividend) assets, just as you would a US taxable account.Stereo1687 wrote: ↑Fri Jun 02, 2023 3:32 pm I think there are at least two things I'd like to confirm if you experts have any thoughts :) :
- it looks like I would be for sure taxed by NZ on my Roth IRA withdrawals?
Yes, it's a major PITA facing tax on accounts that you set up specifically to be tax-free forever, and in good faith. Just a fact of relocation, unfortunately. (Now you know just how UK citizens holding ISAs feel when they move to the US. Or Canadians holding TFSA accounts. Or Japanese holding NISA accounts. Or French holding PEA accounts. And so on. The US does this all the time to new immigrants. In spades, if you factor in likely PFIC nonsense on top.)
As outlined above, yes, but you claim it against US tax, not against NZ tax. As a resident of NZ, it is NZ that has primary taxing rights. The fact that the US uniquely taxes its citizens everywhere and forever just sits on top of the customary residence-based international tax rules.Stereo1687 wrote: ↑Fri Jun 02, 2023 3:32 pm - for my pretax IRAs, it sounds like I can claim a credit when filing by NZ tax return right?
All with the disclaimer that like ray.james, I'm familiar with a handful of US tax treaties, but NZ isn't one I've looked at in detail, and I'm in the UK and with no connection to NZ. Double-check all of the above, then. Tax, international or otherwise, is not my job. I'm just some random bloke on the internet.
Re: New Zealand taxation of US retirement accounts?
I love New Zealand so much but as an American this is one of the reasons why I moved back to the United States after living there for a while.
Re: Made a mistake saving so much in 401k's?
I wouldn't want to DIY this given the amounts involved. One of the links you posted seems to offer advice for this type of situation, I would definitely use them. A company I worked for had a service to help expats deal with taxes. I remember an acquaintance I had in that company intended to settle down in the new country (that was Singapore) and made the decision to withdraw all his 401k and pay the penalty upfront versus allowing it to grow for many years based on the expected taxes, this was the advice he was given. Each situation is different, but if you have Kiwi experts available, I would definitely use them.Stereo1687 wrote: ↑Fri Jun 02, 2023 3:32 pm Thanks all for the help & insights. To explain my situation, when I leave the US I will be leaving my current employer, which means I can rollover into my IRAs. It sounds like that is preferred in case I want to withdraw my contributions
I am really struggling with understanding the tax treaty. It'd be amazing even if I just have to pay the higher of the two countriestax rates, but when I read online posts, it seems to contradict the ray.james' interpretation. Here are two blogs I'm looking at:
https://www.usglobaltax.com/article-us- ... or-expats/
https://www.nzustax.com/nz-tax-treatmen ... -accounts/
I think there are at least two things I'd like to confirm if you experts have any thoughts :
- it looks like I would be for sure taxed by NZ on my Roth IRA withdrawals?
- for my pretax IRAs, it sounds like I can claim a credit when filing by NZ tax return right?
I know this is really arcane & niche, so I'm super grateful for everyone's insights already. If no one knows or has any thoughts that's totally fine - I already appreciate all the effort put in.
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