New Zealand and the United States
What changes when you move from New Zealand to the United States?
A great deal, because the two countries have no social security agreement and the US has no work visa set aside for New Zealanders. Once you pass the US residence tests you are taxed in the US on worldwide income, KiwiSaver included, and your New Zealand accounts go on US reporting forms. Health insurance is yours to arrange: a non-citizen can buy into Medicare only after 5 years as a permanent resident. Your New Zealand working years do not count towards US Social Security, which needs 40 credits, and a year of work earns at most four. Before you go, a student loan starts charging interest once you count as overseas-based, and KiwiSaver can be taken out after a year away, apart from the government's contributions.
Can you just go?
No, and there is no shortcut. Australians have a US work visa of their own, the E-3, and New Zealanders do not. What New Zealand does have, since 10 June 2019, is treaty status for the treaty trader and treaty investor visas, E-1 and E-2, on the State Department's list of treaty countries. Those suit people running trade or an investment between the two countries, not most employees. Anything else starts at the State Department, and this guide does not try to choose for you.
Before you leave New Zealand
You may stay a New Zealand tax resident longer than you think. Inland Revenue only lets you go when you both "do not have a permanent place of abode in New Zealand" and "are away from New Zealand for more than 325 days in any 12-month period". A few people are also caught by a rule for offshore shares and funds: when you become non-resident, "you'll be treated as having sold your interests for market value immediately before the change for the purpose of calculating FIF income."
A student loan stops being interest-free once you are overseas-based, which Inland Revenue puts at "around 5 out of 6 months" away. Interest then runs at 5.6% a year for 2026-27, and repayments are set by the size of the loan rather than your pay.
KiwiSaver can come out, most of it. Emigrating anywhere other than Australia lets you withdraw after you have lived outside New Zealand for a full year, but "You cannot take out the government contributions." Whether to take it is tied up with the next section, because the United States will tax it in its own way whether it stays or comes out.
Your first year in the United States
When the US starts taxing you. A green card makes you resident for tax straight away: "You are a resident, for U.S. federal tax purposes, if you are a lawful permanent resident of the United States at any time during the calendar year." Without one, you are resident once you pass the substantial presence test: "31 days during the current year, and" "183 days during the 3-year period", counting all of this year's days, a third of last year's and a sixth of the year before. "The most common dual-status tax years are the years of arrival and departure", so expect your first year to be split in two.
From then on the US taxes your worldwide income, the way it taxes its citizens. KiwiSaver, New Zealand bank accounts and New Zealand managed funds come with you on to US forms. The FBAR applies once your accounts outside the US together pass $10,000 at any time in the year. And US tax treats many foreign funds as passive foreign investment companies, which the IRS defines by its income and asset tests, not by name. There is no published ruling on whether a New Zealand fund meets them.
Health insurance is yours to arrange. There is no public scheme to join on arrival. "Lawfully present immigrants can get Marketplace coverage and may qualify for the premium tax credit", which is the usual route if a job does not provide cover. Medicare later has conditions of its own: a non-citizen can buy into it only as "An alien lawfully admitted for permanent residence who has resided in the United States continuously for the 5-year period" before, and it is only free of premiums for people who, or whose spouse, "paid Medicare taxes long enough while working", which Medicare puts at generally at least 10 years.
A credit history starts from nothing. Your New Zealand record does not follow you. The Consumer Financial Protection Bureau's suggestions for starting one include a secured card: "You put in an amount of cash, for example $500. Then, you can spend up to that amount on your credit card."
Social Security, without an agreement
The United States has social security agreements with many countries, including Australia, and none with New Zealand. That has two consequences.
Your New Zealand working years do nothing for US Social Security. You need 40 credits to qualify, and a year of work earns at most four, and years elsewhere count as zeros in the average your payment is worked out from.
And if you go home, the payments may not follow you. A New Zealand citizen is paid in New Zealand for six months and then stopped, with no agreement to fall back on. NZ Super, for its part, deducts US Social Security dollar for dollar.
Children born in the United States
A child born overseas to a New Zealand citizen by birth or grant is a New Zealand citizen by descent, and needs registering to get a passport. It passes one generation only: a citizen by descent cannot automatically pass New Zealand citizenship on to their own children born outside New Zealand.
If you go home
US retirement accounts cost more to empty early. Take money from a 401(k) or IRA before 59½ and "Individuals must pay an additional 10% early withdrawal tax unless an exception applies." Once you are no longer a US resident, a plan paying you "must generally withhold 30% of the payment for federal income tax" unless you claim a lower treaty rate.
Keeping US shares has an estate tax edge. After you leave, your estate must file a US estate tax return "if the fair market value at death of the decedent's U.S.-situated assets exceeds $60,000", which includes shares in US companies. The US has an estate and gift tax treaty with Australia, and none with New Zealand.
A long-held green card has an exit rule. You are a long-term resident "if you were a lawful permanent resident of the United States in at least 8 of the last 15 tax years". Giving up that status can bring in the expatriation tax, which applies to anyone whose "net worth is $2 million or more", whose average income tax over the previous five years is above a threshold, or who cannot certify five years of compliance.
What gets easier, and what gets harder
Easier
- Treaty trader and investor visas have been open to New Zealanders since 2019.
- KiwiSaver can come out once you have lived overseas for a year.
- Marketplace health plans are open to lawfully present immigrants.
Harder
- No dedicated work visa, unlike Australians.
- No social security agreement: your New Zealand years don't count, and payments can stop if you go home.
- Health insurance is on you, and Medicare needs 5 years as a permanent resident to buy into.
- KiwiSaver and New Zealand funds sit awkwardly in US tax.
- A credit history starts from nothing.
- Give up a long-held green card and the expatriation tax rules can apply.
What this guide does not tell you
It does not tell you which visa fits you, which is for the State Department and US Citizenship and Immigration Services. It does not work out your US tax, what the tax treaty between the two countries changes, or whether to take KiwiSaver out before you go.
It does not cover state taxes, which differ state by state, or what being born in the US means for a child's citizenship and, later, their taxes. And the one question in the middle of all of it, how the US treats New Zealand managed funds and KiwiSaver as they grow, is one the IRS has never squarely answered.
Sources
- 9 FAM 402.9: Treaty Traders, Investors, and Specialty Occupations (E Visas)
- Tax residency status for individuals
- Leaving New Zealand
- I am going overseas (student loans)
- Student loan interest and fees
- Getting my KiwiSaver funds when I move overseas
- U.S. tax residency: green card test
- Substantial presence test
- Publication 519: U.S. Tax Guide for Aliens
- Report of Foreign Bank and Financial Accounts (FBAR)
- Coverage for lawfully present immigrants
- 42 CFR 406.20: Entitlement to premium Part A
- Medicare costs
- What are some ways to start or rebuild a good credit history?
- U.S. International Social Security Agreements
- Benefits Planner: Social Security Credits and Benefit Eligibility
- Retirement topics: tax on early distributions
- Plan distributions to foreign persons require withholding
- Some nonresidents with U.S. assets must file estate tax returns
- Estate and gift tax treaties (international)
- Expatriation tax
- Instructions for Form 8854
- Types of citizenship: grant, birth and descent
- POMS RS 02610.001: Alien Nonpayment Provisions
- POMS RS 02610.015: Status of Countries for Alien Nonpayment Provision (ANP) Exceptions Based on Citizenship
- Overseas pensions
What no source publishes
Looked for and not found, so this guide gives no figure for it.
- How the US treats a New Zealand managed fund. The IRS publishes the test for a passive foreign investment company, but no IRS page says whether New Zealand funds meet it.