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Robin D.
Robin D., Senior Tax Advisor 4
Category: Tax
Satisfied Customers: 13144
Experience:  15years with H & R Block. Divisional leader, Instructor
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If someone wants to transfer a US Rollover IRA to a Swiss employer-sponsored

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If someone wants to transfer a US Rollover IRA to a Swiss employer-sponsored retirement plan (or a Swiss IRA, if there is such a thing), is that possible to do without the IRS interpreting it as a taxable distribution?

Robin D. :

Hello and thanks for trusting me to help you today. I am a tax adviser with over 15 years of experience.
The IRS would only recognize an account or plan that was under the US for reporting requirements. If the funds were transferred that, unfortunately would not be a rollover in tax terms for deferring the tax.

Robin D. :

The Swiss plan would need to be a qualified plan under the IRC of the US,

Robin D. :

In general if you are under age 59½ at the time of the distribution, any taxable portion not rolled over may be subject to a 10% additional tax on early distributions unless an exception applies.

Robin D. :

Unfortunately, even though there is a tax treaty that addresses pension schemes nothing in the Treaty overrides the requirement that the distribution must qualify as an “eligible rollover distribution” within the meaning of IRC section 402(c)(4).

Robin D. :

I sincerely XXXXX XXXXX could tell you differently but thank you in advance for a positive rating.

Robin D. :

My goal is to give you excellent service. If you are satisfied, please rate me. If you have follow-up questions on this same topic, use the reply box below. To start a new conversation with me on a new topic request me again.

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Customer: replied 3 years ago.

So to clarify, even though the funds could be transferred, it would be considered a taxable distribution by the IRS?

Yes, unfortunately that is correct.

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