Transferring a 401k or IRA Internationally (ie

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Does anyone have more knowledge of this and want to contradict me, correct me, or tell this questionnaire how to trasfer a 401(K) to Australia?
.
Hi
I recently sent through the query below but received no reply, other than
to be put on a mailing list.
If you are unable to answer the question, please advise,
But at the same time, please remove my email address from your list.
Regards
MXXXXXXXXXXX
                                      
Hi Taxman,
I work in Australia and have a client with around US$500,000 in a 401K plan
that he would like to transfer to Australia, and was wondering if you knew
if this could occur and if so where in a position to help with the
transfer.
Could you please let me know if it is possible to transfer a 401K
internationally and what assistance you might offer with this ?
Thanks
Regards
MXCCCCCCCC
SYDNEY NSW 2000
===============================================================
david ingram replies:
Forget it. 
I am positive that the legislation allows the transfer but numerous attempts and many wasted hours have never resulted in an official comfort letter which would satisfy the present holder of the funds that they can release the funds without a withholding tax.
Between Canada and the US, Article XVIII of our treaty would seem to allow it.  None of the US financial institutions will agree without a comfort letter from the IRS.
Australia and New Zealand are caught in the same bind.
david ingram
PS - let me know if you find otherwise.
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