If you have worked in the United States it is likely that you have paid into a US retirement account such as an IRA (Individual Retirement Arrangement) or a 401k (a company-sponsored retirement plan). The question arises as to what should be done with such an account once you give up US residency.
There are three alternatives: You can transfer it to another type of retirement account, you can distribute the money, or you can leave it in the current account.
In an ideal world you would have complete cross-border portability for your US retirement account such that you could transfer the funds without tax consequences to an equivalent account in your new country of residency. Unfortunately US tax regulations typically do not allow such transfers. While you can sometimes transfer from one type of US plan to another without tax consequences (such as from a 401k to an IRA), it is usually not possible to transfer from a US plan to a non-US plan; with the possible exception of some specially structured corporate pension plans.
This brings us to the second option: You could withdraw the funds in your US plan and do what you like with the proceeds. US retirement plans are quite flexible in terms of allowing access to one’s funds. Unlike retirement and pension accounts in many other countries that may allow only limited lump-sum withdrawals and only once a certain age is reached, you can access any or all of the funds in a US IRA at any time. If you have a 401k account from a former employer, this can be transferred to an IRA (“rolled over” in the vernacular), whereupon the funds can be accessed as above. Other types of US plans, such as deferred compensation plans or defined benefit plans are less flexible.
The downsides of withdrawing the funds from your retirement plan are that you lose the tax-deferral benefits, which may be substantial over time, and the distributed funds may be subject to taxes and possibly a 10% penalty for early withdrawal if you are under age 59 1⁄2. Taxes are typically due on amounts that have been contributed pre-tax to 401k and Traditional IRA accounts and on the earnings in these accounts. Roth IRAs and Roth 401ks are funded with after-tax money and therefore there is no US tax to be paid when funds are withdrawn.
US accounts also typically offer substantial investor protection in the form of insurance against the default of the financial institution holding the account. Such protection may be much more limited or even non-existent in other countries, especially many offshore jurisdictions.
The third option is to leave the account as is, to be accessed as the need arises in retirement or otherwise, once early withdrawal penalties no longer apply. This is the best option for many people but the issue non-US residents often face is that their US retirement plan administrator may not be willing to deal with them now that they no longer live in the United States. Many brokerage firms will insist that you close your account once you are no longer a US resident or they may allow you to retain the account but will not allow management of the investments – in effect freezing the account. Increasingly American expatriates are turning to firms that specialize in investment management for non-US residents in order to deal with these issues.
Apart from the administrative issues faced by leaving the account as is, another concern may be currency risk. Typically US retirement accounts are invested mostly in US Dollar denominated investments, but if you reside outside the USA you may eventually spend the funds in another currency. This can introduce significant currency risk in addition to the investment risk you may already be assuming. For example, someone with a US-based retirement account who moved abroad at the beginning of 2002 but left their investments in USD denominated assets may have suffered significant loss of purchasing power over the next ten years as the USD weakened by 33% vs. the Euro, by 11% vs. the British Pound, by 38% vs. the Canadian Dollar, and by 50% vs. the Australian Dollar.
Clearly it is important to consider currency risk if you may eventually be spending your retirement funds in a currency different from that in which they are invested. Many US brokerage firms and investment advisors do not consider this and maintain only a minimal allocation to non-US investments. Also, typically retirement accounts such as 401ks only offer very limited non-US investment options so it may be to your benefit to terminate such plans once you are no longer a US resident and move the money to an IRA where it can be more globally diversified.
One final consideration is the tax status of your US retirement account in your current country of residency. The United States has income tax treaties with many countries that allow for mutual deferral of taxation on certain types of retirement and pension accounts. However, there are also many countries that do not have a tax treaty with the USA, or where the tax treaty only applies to certain types of US tax-deferred accounts and not to others – in such an instance your US tax-deferred account may not be tax-deferred in your country of residency.
In summary: US retirement accounts such as IRAs and 401ks typically cannot be moved to an equivalent account in a different country without distributing the accounts for US tax purposes and paying tax and possibly early withdrawal penalties. For this reason it is often best to keep the money in a US retirement account to be drawn on as needed. Important considerations if maintaining the US account are currency risk and whether the account maintains its tax-deferred status in the country of residency.
