Can I move my 401(k) or IRA into KiwiSaver or Australian super?

Can a 401(k) or IRA be rolled over into KiwiSaver or super?

No. A rollover is the US way of moving retirement money without paying tax on it, and it only works between particular kinds of account.

The IRS defines it this way: "A rollover occurs when you withdraw cash or other assets from one eligible retirement plan and contribute all or part of it, within 60 days, to another eligible retirement plan."

The plans it lists as able to take a rollover are all US ones: 401(k) and other qualified plans, 403(b) and governmental 457(b) plans, and traditional, Roth, SEP and SIMPLE IRAs. Neither its rollover guidance nor its rollover chart names a KiwiSaver scheme, an Australian super fund, or any foreign scheme at all.

That leaves the other side of the rule. The IRS says: "You must include the taxable amount of a distribution that you don't roll over in income in the year of the distribution."

So there is no transfer route like the one between Australian super and KiwiSaver. Getting the money across is a two-step job: take it out of the US account, then put it into KiwiSaver or super under that country's rules.

What does taking the money out cost in the United States?

Income tax on the taxable part, and possibly an extra 10%.

The additional tax. Before 59½, most withdrawals attract it. The IRS: "The additional tax is equal to 10% of the portion of the distribution that's includible in gross income." It is on top of ordinary income tax, not instead of it.

There are exceptions, and they differ between the two kinds of account. For a 401(k), Publication 575 exempts distributions "from a qualified retirement plan after your separation from service in or after the year you reached age 55". Publication 590-B's list of exceptions for IRAs does not include that one. There is a separate guide on what happens if you need the money early.

A Roth account is taxed differently when the money comes out, and this guide does not go into how.

How much is held back before the money reaches me?

Some tax is usually taken off at source, and how much depends on the account and on who you are for US tax purposes.

• From a 401(k), a payment made to you is "subject to mandatory income tax withholding (generally at a rate of 20%)", in the IRS's words.
• From a traditional IRA, "tax will be withheld at a 10% rate on nonperiodic payments" as a general rule. A US citizen or resident alien whose home address is outside the United States "can't choose exemption from withholding".
• If you are not a US citizen or resident, the IRS's guidance for payers says that without a treaty exemption they must withhold "at the statutory rate of 30% on the entire distribution that is from sources within the United States". It adds that most tax treaties exempt non-government pensions, but that the exemption "may not apply to lump-sum payments".

Withholding is money held back towards the tax. The IRS notes that "the default rate of withholding may be too low for your tax situation".

What does New Zealand do with it?

Once you are a New Zealand tax resident, New Zealand's foreign superannuation rules apply, and they apply whichever way the money travels.

Inland Revenue's guide IR1024 defines a lump sum as "A single payment paid to you directly, or transferred to your New Zealand or Australian superannuation scheme." Taking the money into your bank account and paying it into KiwiSaver yourself does not avoid the rules.

In your first four years of New Zealand tax residence, a lump sum is not taxed here. After that, part of it is taxed, worked out with the schedule method or the formula method. The guide on how a 401(k) or IRA is taxed in New Zealand goes through the four year window and both methods.

One caveat. Inland Revenue defines foreign superannuation as "funds created outside of New Zealand to provide retirement benefits to individuals". Its guidance does not name 401(k) plans or IRAs, and the example IR1024 gives is United Kingdom pension schemes.

Can the money go into KiwiSaver?

Yes, as a voluntary contribution. Inland Revenue says you can pay into your KiwiSaver account voluntarily at any time, directly to your provider or through Inland Revenue. Its page on these payments does not mention an upper limit.

Before you do, weigh this: "Once you've made a voluntary payment it's locked in until you're eligible to withdraw your savings (currently 65)."

Money that the IRS would have let you take from a 401(k) or IRA without the additional tax from 59½ is, once in KiwiSaver, locked away until 65.

Paying the New Zealand tax. A lump sum moved into KiwiSaver can leave a tax bill with no cash to pay it from. The Act allows for that. Clause 14C of the KiwiSaver scheme rules lets a member withdraw enough to pay the tax "arising under the Income Tax Act 2007 from the member's withdrawal of an interest in a foreign superannuation scheme and conversion of the interest into an interest in a KiwiSaver scheme". The withdrawal is capped at the lesser of that tax and your terminal tax for the year. You have to apply within 24 months of the end of the month the tax is assessed, with a statutory declaration.

Some schemes also offer a "scheme pays" option. Inland Revenue says that if your New Zealand scheme offers it, you can ask the scheme to pay 28% tax on the taxable portion to Inland Revenue out of the transferred money.

What does Australia do with it?

The ATO describes two ways to get money out of a foreign super fund: transfer it to a complying Australian super fund, or withdraw it directly as a lump sum. It adds that a foreign super fund "may be known in its home country as a retirement fund, pension fund, retirement savings plan or similar".

It is also clear that Australia does not decide whether you can move it: "Whether you can transfer or withdraw money from a foreign super fund will depend on the fund's rules and the laws of its home country." For a 401(k) or an IRA, that means the US rules above.

What Australia taxes is the applicable fund earnings, which the ATO describes as "the earnings on your foreign super interest that have accrued since you became an Australian resident for tax purposes". The rest of the lump sum is tax-free.

Timing matters. If you take the money within six months of becoming an Australian resident, or of your foreign job ending, none of it counts as applicable fund earnings, as long as the ATO's conditions are met.

After six months, the applicable fund earnings go in your own tax return. There is one alternative. If you transfer the whole of your interest directly into a complying Australian fund and keep nothing in the foreign fund, you can choose to have some or all of those earnings taxed in the fund instead, at 15%.

Your Australian fund must also have your tax file number. If it does not have it within 30 days of the transfer, the ATO says the fund must send the whole amount back.

Does it count towards the Australian contribution caps?

Yes. The ATO: "A transfer from a foreign super fund to a complying Australian super fund is treated as a member contribution." Most of it counts towards your non-concessional contributions cap.

From 1 July 2026 that cap is $130,000 a year. It is nil if your total super balance was $2.1 million or more on the previous 30 June. If you are under 75 and your balance was under $1.84 million, the bring-forward arrangement lets you put in up to $390,000 over three years. Go over the cap and the ATO sends a determination, and the excess may be taxed.

The caps follow the money whichever way it arrives. The non-concessional cap is the limit on after-tax contributions each year, so money you withdraw yourself and then pay into super counts towards it too. The ATO lists personal contributions among the voluntary contributions a fund can accept from anyone under 75.

A large US balance may therefore take more than one year to bring into super without extra tax.

What this guide does not tell you

It does not tell you whether moving the money is a good idea. Fees, investment choice, currency, the tax you would pay in each country and when you will need the money all decide that, and they are questions for an adviser who knows both systems.

It does not deal with the tax treaties between the United States and New Zealand or Australia. Inland Revenue points out that a double tax agreement "can affect how you're taxed", and a treaty may change both the US withholding and the tax in the country you live in. Nor does it cover how a US citizen or green card holder reports the withdrawal, which is part of the wider question of filing a US tax return from New Zealand.

Also left alone: Roth accounts, taking the money as regular payments rather than a lump sum, and how a withdrawal affects Working for Families, student loans or an Australian or New Zealand pension.

No published ruling or guidance was found on three points. Neither Inland Revenue nor the ATO names a 401(k) or an IRA when it describes the foreign schemes its rules cover. And neither the IRS nor either tax office says whether a US plan or IRA provider can pay the money straight to a KiwiSaver scheme or an Australian super fund rather than to you. If your plans turn on any of these, ask your US provider and a tax adviser in the country you live in before you move anything.