Distribution to Resident Alien

[Guest abajeb]

We have a guy that wants to roll money over to an account in Australia. What is the tax treatment of this kind of transaction? I'm thinking it's a taxable distribution subject to the regular income taxes and penalties for early withdrawal, but I can't find anything to support this. Anyone out there know how to handle this, or where I can look for more info? Thanks.

JB

[Guest b2kates]

the issue is resolved in 408, under who is a qualified IRA custodian. it is my recollection that only US banks, insurance companies and mutual funds generally qualify. In the past when a participant would transfer to other custodians, we treated it as a tax able distribution reportable on form 1099R