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Plan is sponsored by US company owned by a foreign company. French citizen that has been working at US company and participating in the 401k is leaving the US company and returning to France to work for the "mother" company.

I believe there are no issues with making a distribution.

What are the tax/rollover issues for a foreign citizen (French) to take a rollover? Is there a treaty that determines when the distribution is taxed or if there is a special provision for foreigners?

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