
TL;DR: Moving from the US to Australia triggers a cascade of financial decisions covering your home, retirement accounts, taxable investments, and foreign account reporting that can lock in your tax treatment for years. The decisions you make in the months before and after landing determine whether you pay tax once or twice.
Every visa guide will walk you through the 482, the 189, the 190. What none of them cover is what happens to your money. Moving from the US to Australia means stepping into an overlap between two tax systems that both claim the right to tax your worldwide income, and the financial decisions you make in the 12 months surrounding your move will shape your tax architecture for years. For a broader grounding before we go deep, see our financial dos and don'ts for Americans moving to Australia.
Cross-border financial planning for an American moving to Australia is the discipline of sequencing financial decisions on taxes, accounts, and investments across two jurisdictions that both claim the right to tax you.
The United States taxes its citizens on worldwide income regardless of where they live. Australia taxes residents on worldwide income from the day they arrive. That overlap is the default outcome if nothing is structured.
To make that concrete: meet Sofia and James. Both 38, relocating from San Francisco to Sydney on 482 visas. They have $800,000 (USD) in US retirement accounts and $400,000 (USD) in a taxable brokerage portfolio. The visa is handled. This post picks up where that guide ends.
Their move has three financial phases: the decisions made before departure, the actions required in the first 30 days, and the structuring work of the first full year. Each phase creates conditions the next one depends on, and the order matters.
The US primary-residence capital gains exclusion applies to US citizens, but eligibility depends on meeting a use test, and once Sofia and James leave, the clock on that test runs down. The timing of any home sale relative to their departure date affects whether they qualify. This decision needs to be made before they board the plane.
If they keep the property and rent it out, US non-resident landlord rules apply on the US side, and Australian-side income treatment applies to the rental income they receive as Australian tax residents. They also need a plan for depreciation recapture, which the Australian Tax Office (ATO) treats differently than the IRS. Naming a strategy for the property before departure is a pre-move decision, and leaving it unresolved is not a neutral choice.
Once Sofia and James establish Australian tax residency, the US-Australia Tax Treaty becomes their operating framework for how retirement account income is taxed on both sides. Article 18 of that treaty contains provisions that can affect the tax treatment of retirement contributions and distributions, but the elections available and their conditions depend on how their accounts are structured before they arrive.
Rolling a 401(k) to an Individual Retirement Account (IRA) while still a US tax resident is a purely domestic transaction with no Australian tax consequence. Completing that rollover after establishing Australian residency may receive different treatment. Getting this wrong may foreclose treaty options that would otherwise be available for years of future distributions.
The full mechanics deserve more space than a single section can give them. Watch our on-demand webinar, Bringing Your US Accounts (401k / IRA) to Australia, to understand every option, including rollover, treaty election, and timing, before making a move you can't undo. For the complete treatment of rollover strategy, see our dedicated post on moving your US retirement accounts to Australia.
Compliance obligations begin the moment Sofia and James land, not when they file their first Australian tax return.
Under the Foreign Account Tax Compliance Act (FATCA), US persons must report foreign financial assets on Form 8938 if they exceed applicable thresholds. That obligation begins in the tax year the account is opened, not the year it grows.
A Passive Foreign Investment Company, or PFIC, is a foreign corporation meeting specific income or asset tests under US tax law. Most Australian-domiciled managed funds and exchange-traded funds (ETFs) qualify, making them potentially punitive for US taxpayers who hold them without a compliance plan.
Under IRC §1297, as confirmed by the IRS Form 8621 instructions, a foreign corporation is a PFIC if 75% or more of its gross income is passive, or 50% or more of its average assets produce passive income. Australian-domiciled index funds and managed funds meet these tests almost by definition. The tax treatment of PFIC gains can be punitive, with interest charges applied retroactively to the year of investment.
Sofia and James should structure their Australian investment portfolio to avoid PFIC exposure from the moment they open a brokerage account in Australia, not in year three when they file. For the full framework, see our guide on how PFICs affect Australian expats who are US tax residents.
From day one of employment in Australia, Sofia will begin receiving compulsory employer superannuation (the Australian retirement savings system) contributions. We know that the IRS does not recognize Australian superannuation as the equivalent of a US 401(k) or IRA, and the US-Australia tax treaty lacks a specific deferral provision for superannuation contributions. Without a treaty election under Article 18, those contributions may be treated as taxable income on the US side in the year received, and if contributions are mis-handled, it may result in the Superannuation account being treated as a Foreign Grantor Trust (making any gains taxable in the US annually).
The election is time-sensitive and must be made correctly. The mechanics are covered in our post on US tax rules for Australian retirement accounts.
In month one, Sofia and James opened the bank account, notified their US brokerage, and began the 401(k)-to-IRA evaluation. In month six, they are reviewing the PFIC structure of their Australian brokerage, confirming the superannuation treaty election, and preparing their first dual-country tax filing. The decisions in month one made the decisions in month six possible.
If they had bought Australian ETFs in week two without understanding PFIC rules, remediation would be expensive and structurally complex. If they had deferred the 401(k) rollover evaluation until after establishing Australian residency, certain treaty-favourable options may have already closed.
When moving from the US to Australia, the financial decisions made early in the move can significantly influence the tax structure for years to come. Getting those decisions wrong can mean years of paying tax twice on the same money.
Areté Wealth Strategists specializes in exactly this kind of transition. Our cross-border financial planning process is designed to help clients sequence key decisions before and after their move. According to ABS Overseas Migration data, net overseas migration to Australia was 306,000 in 2024-25, a significant number of people facing these decisions (possibly) without a roadmap.
If you're planning your move in the next 12 months, schedule a 15-minute Fit Call with Areté Wealth Strategists to see if our expertise matches your needs, before the visa is stamped.
Q: Do I still owe US taxes after moving to Australia?
The United States taxes its citizens on worldwide income regardless of where they live. Moving to Australia ends your Australian non-resident status and starts your Australian tax obligations, but it does not end your US filing obligation as a citizen. You will file in both countries, and the US-Australia tax treaty determines how credits and exemptions reduce, though rarely eliminate, the overlap.
Q: What happens to my 401(k) when I move to Australia?
Your 401(k) remains in the US and cannot be transferred directly into Australian superannuation. Under Article 18 of the US-Australia Tax Treaty, there are elections that can affect how future distributions are taxed on the Australian side. The pre-move window, before you establish Australian tax residency, is when the most consequential decisions about your retirement accounts get made.
This article is for informational purposes only and does not constitute tax, legal, or financial advice. Cross-border tax rules change frequently. Consult a qualified cross-border advisor before making any decisions.

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