Moving from the US to Australia or New Zealand: A Tax Guide for Expats

Moving from US to Australia or moving from US to New Zealand means picking a country, then a visa, then a plan for your money. Australia offers the American-only E-3 visa plus skilled and employer routes; New Zealand runs on the Accredited Employer Work Visa and the Green List. Australia pays more but costs more; New Zealand is quieter with lower salaries but a four-year tax break and no capital gains tax. On tax, both countries tax you as a resident and the US still taxes you as a citizen, so you file twice. Treaties and the foreign tax credit usually erase the US bill, but super and KiwiSaver are where Americans get burned.

Key Takeaways

Which is easier to enter? Australia has the American-only E-3 work visa; New Zealand leans on the Accredited Employer Work Visa and Green List. Neither offers an easy over-30 working-holiday route.

Do you still owe US taxes? Yes. Both countries tax residents, and the US taxes citizens, so you file in two places.

Double taxed? Rarely, thanks to each country's US tax treaty and the foreign tax credit.

The big trap? Australian superannuation and New Zealand's KiwiSaver, which the IRS can treat as foreign trusts or PFICs.

Self-employed? Australia has a Social Security agreement with the US; New Zealand does not, which can mean full US self-employment tax.

Australia and New Zealand sit at the top of almost every American's “where could I actually move” list, and for good reason: English-speaking, stable, outdoors-obsessed, with universal healthcare and a slower pace. But the two countries are not interchangeable, and the move is more structured than a long holiday. Whether you are US expat moving to Australia or US expat moving to New Zealand, you need a visa that matches your actual reason for going and a plan for the part almost everyone underestimates: your US tax obligations after moving abroad. This guide compares both countries side by side, in the order you will face the decisions, and it is current for 2026.

Visa and Immigration: How to Move to Australia or New Zealand from the US

There is no arrive-and-look-for-work route to either country. You need a visa tied to work, skills, family, study, or investment, and the systems, while similar in spirit, differ in the details.

Australia: The E-3 Advantage

Australia's standout for Americans is the E-3 visa, open only to US citizens with a professional job offer. It is faster and cheaper than most alternatives, skips the points test, and lets spouses work, though it does not lead directly to permanent residency. The main routes are the employer-sponsored 482 (a medium-term stream leads to PR via the 186), the points-tested skilled independent 189 and nominated 190, and the fast Global Talent 858 for standout tech and STEM professionals. One gap: Americans over 30 have no Working Holiday option, so casual arrival is not a plan.

New Zealand: Employer-Led and the Green List

New Zealand's system runs on the Accredited Employer Work Visa (AEWV), which needs a job offer from an accredited employer paying at or above the median wage. If your occupation is on the Green List of shortage roles, Tier 1 can take you Straight to Residence, while Tier 2 requires two years of NZ work first. The points-based Skilled Migrant Category is the classic residence route for those 55 and under, and Americans aged 18 to 30 can use a capped Working Holiday visa. Watch for August 2026 changes adding new skilled pathways.

Australia or New Zealand: Which One Fits You?

Because the two countries pull in different directions, the smarter question is not “which is better” but “which fits me.” US expats in Australia tend to prioritize higher pay, a bigger job market, and the E-3 shortcut, while US expats in New Zealand more often want a quieter pace and the country's tax quirks. Weigh four things before you commit:

• Career and pay. Australian wages run 20 to 30% higher than New Zealand's for equivalent roles, with a larger market in tech, healthcare, and finance. New Zealand is smaller and lower-paid but often less pressured.
• Getting in. The E-3 is a genuine US-only advantage in Australia; New Zealand's Green List fast-tracks shortage occupations straight to residence.
• If you are self-employed. Australia has a Social Security agreement with the US, so freelancers usually avoid double social-security tax. New Zealand has none, so US self-employment tax can stack on top of NZ tax.
• Tax perks. New Zealand offers new residents a roughly four-year break on most foreign income and has no general capital gains tax; Australia taxes capital gains but has a richer compulsory retirement scheme.
  
  

On healthcare, both are strong: Australia's Medicare generally begins with permanent residency (carry private cover until then), while New Zealand's public system opens up on a resident visa or a work visa of two years or more, with ACC covering accident injuries for everyone.

Do US Citizens Still Pay US Taxes After Moving Abroad?

This is the reality that catches people off guard. The US taxes its citizens on worldwide income no matter where they live, so your US tax obligations for Americans living abroad do not end when you land in Sydney or Auckland. You become a tax resident of your new country and still file a US return every year, which means dual filing. Handling US taxes when moving to Australia or US taxes when moving to New Zealand well is mostly about claiming the right relief so you are not taxed twice.

The reassuring news is that US taxes for Americans living overseas rarely produce a second bill once treaties and credits are applied. Both countries have US tax treaties and higher effective rates than the US on most salaries, so the foreign tax credit usually wipes out what you would otherwise owe. The obligation that never goes away is the filing itself.

Australia vs. New Zealand: Tax at a Glance

Three rows on this table matter most for a US citizen. First, the retirement schemes cut the opposite way from how locals see them: both super and KiwiSaver can be treated by the IRS as foreign trusts or as holding PFICs, so the account that looks like a tax win locally can generate US tax and heavy reporting. Second, self-employment is where the two countries genuinely diverge, because Australia’s totalization agreement spares freelancers a second Social Security bill while New Zealand’s absence of one can add the full 15.3% US self-employment tax. Third, New Zealand’s four-year foreign-income exemption and lack of a general CGT create a real planning window, but only for New Zealand tax, the US still taxes that same income, so the two systems have to be coordinated rather than assumed to line up.

Avoiding Double Taxation: Treaties, the Credit, and the Exclusion

Three tools keep the same dollar from being taxed twice, and the best mix differs between the two countries.

• Tax treaties. The US-Australia and US-New Zealand treaties coordinate which country taxes what and reduce withholding on dividends, interest, and royalties. Both keep a “saving clause” that preserves the US right to tax its citizens, so a treaty reduces double tax but never ends your filing.
• The Foreign Tax Credit (FTC). A dollar-for-dollar US credit for income tax you already paid locally (Form 1116). In high-tax Australia it almost always erases the US bill; in New Zealand, whose rates are a little lower, it still helps most filers.
• The Foreign Earned Income Exclusion (FEIE). Excludes up to $132,900 of earned income for 2026 (Form 2555). It suits lower or moderate earners, and some New Zealand expats use it for salary and the FTC for investment income; revoking it triggers a five-year lockout.

Handled well, US expat taxes in Australia and US expat taxes in New Zealand usually settle at or near zero owed to the IRS. One quirk trips up newcomers, though: the tax years do not line up. Australia runs July to June and New Zealand April to March, while the US runs on the calendar year, so income has to be re-sorted into US periods before credits can be matched. It is fiddly, but routine for a cross-border preparer.

Superannuation and KiwiSaver: Where Americans Get Burned

Here is the single most expensive mistake in either country, and the reason a generic expat guide is not enough. The retirement accounts locals treat as obvious winners can be actively harmful for a US citizen, because the IRS does not recognize their favored status.

Australian Superannuation

Super is compulsory (employer contributions are around 11.5%), and locals rarely think about its tax. For a US citizen it is a minefield: the IRS may treat your fund as a foreign trust, so employer contributions can be taxable to you in the year they are made, the fund may owe Forms 3520 and 3520-A, and investments inside it can be PFICs each needing Form 8621. Self-managed super funds (SMSFs) are worse, since every underlying asset can carry its own reporting. The treaty offers some relief, but positions must be taken deliberately.

New Zealand KiwiSaver

KiwiSaver has the same problem in a smaller package. The IRS can treat it as a foreign grantor trust or hold its funds to be PFICs, pulling in Form 3520 or Form 8621, and it is reportable on FBAR. Enrolling without advice, or opting your US-citizen children in automatically, can create reporting headaches out of proportion to the balance. Get cross-border advice before you enroll or increase contributions.

What Happens to My U.S. Investments?

One of the most common questions before a move is what to do with the 401(k), IRA, and brokerage account you already hold in the US. The reassuring answer: your US retirement accounts generally travel well. A 401(k) and traditional IRA stay tax-deferred, and both the US-Australia and US-New Zealand treaties help coordinate how withdrawals are taxed later, though the timing and treatment of distributions differ, so take advice before you draw on them. A Roth IRA is more nuanced abroad, so confirm how your new country views it before relying on tax-free growth.

Your US brokerage account and US-domiciled funds are the safe place to hold investments as an expat. US mutual funds and ETFs are not PFICs, so they avoid the punitive regime that catches locally bought funds. The trap is the reverse: buying Australian or New Zealand mutual funds or ETFs almost always creates PFICs, each demanding a separate Form 8621 with taxation that can approach the highest US rates. The cleaner path for most Americans is to keep investing through a US brokerage and avoid local pooled funds outside a treaty-protected wrapper. Note too that some US brokerages restrict or close accounts once you have a foreign address, so confirm your provider’s policy before you leave and keep a US mailing address only if it genuinely remains valid.

Whatever you hold, the income still flows onto your US return: dividends, interest, and capital gains from your US investments remain US-taxable, and once you are a resident of Australia or New Zealand they are generally taxable there too. The foreign tax credit is what stops the same dollar being taxed twice, so coordinating where each type of income is taxed, and in which year, is the heart of getting investment income right after the move.

US Tax Filing While Living in Australia or New Zealand: Forms and Deadlines

Beyond the return, US tax filing while living in Australia and US tax filing while living in New Zealand bring information forms with heavy penalties even when no tax is owed. If your local accounts (including super or KiwiSaver) top $10,000 combined at any point, you file an FBAR (FinCEN Form 114). FATCA can add Form 8938 above higher thresholds ($200,000 at year-end or $300,000 at any time for single filers abroad, and $400,000 at year-end or $600,000 at any time for those married filing jointly abroad). Both countries share account data with the IRS under FATCA agreements, so non-filing is not a quiet option.

Timing is forgiving: Americans abroad get an automatic extension to June 15, and to October 15 on request, though interest still accrues from April 15 on anything owed.

Special Tax Situations Every US Expat Should Know

New Zealand's Four-Year Tax Holiday

New Zealand offers new tax residents a transitional resident exemption: for up to four years, most foreign-sourced income is exempt from New Zealand tax. It is a genuine planning window, but it is a one-time, time-limited benefit, and it does nothing for your US return, since the US still taxes that same income. Coordinating the two is where real savings hide, and where people who ignore it overpay.The exemption does not generally cover foreign employment or personal-services income.

Self-Employment and Social Security

This is a sharp difference between the two countries. The US and Australia have a totalization agreement, so self-employed Americans in Australia generally avoid paying Social Security tax to both systems. New Zealand has no such agreement, which means a self-employed American there can owe the full 15.3% US self-employment tax on top of New Zealand tax. If you plan to freelance or run a business, this alone can tilt the decision.

Estate and Gift Tax: A Cross-Border Blind Spot

Neither Australia nor New Zealand levies inheritance or estate tax, which sounds like a clean win. But the US taxes its citizens' worldwide estates and gifts wherever they live, so the tax you escaped locally can still reach your heirs through the IRS. A will drawn up locally may not do what you expect. Anyone with meaningful assets or property in more than one country should build a cross-border estate plan rather than assume the local rules are the whole story.

The Move Year and State Taxes

The year you relocate is the messiest to file, since you may be a US resident for part of it and a foreign resident for the rest, which changes how the exclusion's day tests apply. And do not forget the states: “sticky” states like California can keep taxing you until you sever ties. Getting the taxes for a US citizen living in Australia, or the taxes for a US citizen living in New Zealand, right in that first split year is where good planning pays off.

Smart Tax Moves to Make Before You Leave the US

The biggest tax savings usually happen before you board the plane, not after. A handful of moves in your final US months are hard or impossible to undo once you are a foreign tax resident, so plan them deliberately.

• Sell your US home while the exclusion still applies. If it was your main home for two of the last five years, Section 121 lets you exclude up to $250,000 of gain ($500,000 married). You keep that window for a limited time after moving, so do not let it lapse, and watch for depreciation recapture if you rented it out.
• Time capital gains around your residency date. The US taxes your gains either way, but your new country may tax them too once you are resident. Australia has capital gains tax, while New Zealand's four-year exemption can shelter foreign gains for a while. Realizing gains before foreign residency begins, or inside New Zealand's window, can avoid a second layer of tax.
• Consider a Roth conversion before you go. Converting a traditional IRA to a Roth while you still control your US bracket can lock in tax-free growth. Once you are abroad, your new country's rules and the treaty can complicate the benefit, so model it with an advisor first.
• Keep investing through a US brokerage. Buying local mutual funds or ETFs abroad usually creates PFICs and Form 8621; holding US-domiciled funds sidesteps that trap entirely.

The Tax Breaks Americans Abroad Miss

Filing from abroad is not only about avoiding double tax. Several breaks can put money back in your pocket, and the most valuable one hinges on a single choice between the two relief methods.

• The Child Tax Credit, but only with the right election. For 2025 it is worth up to $2,200 per child, with up to $1,700 refundable as cash even if you owe nothing. The catch: if you use the Foreign Earned Income Exclusion (Form 2555), you forfeit the refundable portion entirely. Families who use the Foreign Tax Credit instead keep it, often turning a $0 return into a real refund. Each child and at least one parent needs a valid Social Security number.
• The foreign housing exclusion. On top of the FEIE, you can exclude part of your rent and housing costs, and high-cost cities such as Sydney carry a larger cap.
• Foreign tax credit carryforwards. Unused foreign tax credits carry back one year and forward ten, so a high-tax year abroad can shelter a future US-income year, worth banking if you might move home or to a lower-tax country later.
• Choosing the credit over the exclusion on purpose. Beyond the child credit, the Foreign Tax Credit avoids the FEIE “stacking” rule that can push your remaining income into a higher bracket.

Your First Year Abroad: A Practical Timeline

The move goes smoothest when the money and tax steps happen in the right order.

Before you move

• Choose your country and visa, and confirm settlement funds, skills assessments, and any occupational registration.
• Get cross-border tax advice and inventory your US accounts (401(k), IRA, brokerage) before you become a foreign resident.
• Plan around New Zealand's four-year exemption if NZ is your destination, and line up private health cover for any waiting period.

Your first few weeks

• Open a local bank account and expect to complete a W-9 or self-certification for FATCA.
• Pause before enrolling in extra superannuation contributions or KiwiSaver until you have had advice.

Your first tax season

• File in both countries, claim the foreign tax credit, and file FBAR and Form 8938 if you cross the thresholds.
• Report super or KiwiSaver correctly, and re-sort income across the mismatched tax years.

How NSKT Global Can Help

The tax side is where the upside of the move is won or lost, and it rewards experience with both systems. NSKT Global handles US expat tax in Australia and US expat tax in New Zealand from end to end: worldwide-income returns on Form 1040, treaty and foreign tax credit planning, superannuation and KiwiSaver trust reporting, PFIC and Form 8621 analysis, FBAR and FATCA filing, New Zealand transitional-resident planning, cross-border estate planning, pre-departure tax planning, and the awkward split-year return in the year you move.

Whether you are US expats in Australia on an E-3, US expats in New Zealand on an Accredited Employer Work Visa, or American expats in Australia and American expats in New Zealand who are already settled and behind on filings, our cross-border team keeps you compliant on both sides while claiming every credit you are owed. Book a consultation and we will map out exactly what applies to you.

People Also Ask

Q: Is it easier for an American to move to Australia or New Zealand?

It depends on your work. Australia has the American-only E-3 visa, which is fast and cheap if you have a professional job offer, giving the US a genuine edge there. New Zealand relies on an accredited-employer job offer or a Green List occupation. Neither has an easy route for Americans over 30 without a job, skills, or family tie, so line up the visa before anything else.

Q: Do I have to keep filing US taxes if I become a citizen of Australia or New Zealand?

Yes. US citizenship carries lifelong filing obligations regardless of any second citizenship, and both countries allow dual citizenship. You keep filing a US return every year until you formally renounce, which has its own tax consequences. Becoming Australian or a New Zealander does not switch off the IRS.

Q: What happens to my US 401(k) and IRA when I move?

They generally stay tax-deferred, and both the US-Australia and US-New Zealand treaties help coordinate retirement income, though withdrawal taxation varies. You usually stop contributing once you are a foreign resident. Get advice before moving any retirement money, and never assume local rules mirror US ones.

Q: Why is my Australian super or New Zealand KiwiSaver a US tax problem?

Because the IRS does not recognize their tax-favored status. It may treat super or KiwiSaver as a foreign trust (Forms 3520 and 3520-A) or hold the underlying funds to be PFICs (Form 8621), and both are reportable on FBAR. Employer super contributions can even be taxable to you currently on the US side. Advice before enrolling or topping up is essential.

Q: Does New Zealand really have a four-year tax-free period?

For New Zealand tax, largely yes. New transitional residents can have most foreign-sourced income exempt from NZ tax for up to about four years. But it is one-time and time-limited, and it does not touch your US return, since the US taxes that income anyway. Used deliberately, it is a real planning window; ignored, it is a missed one.

Q: Will I be double taxed on my salary?

Often, but not always. Double taxation can frequently be reduced or eliminated through the foreign tax credit and treaty provisions, but the result depends on the type and source of the income, your particular circumstances, and the rules of both countries. For salary in higher-tax Australia (and, to a lesser degree, New Zealand), the credit usually erases the US tax on your wages. The relief must be claimed on your return; it is not automatic.

Q: I am self-employed. Does the country I choose change my US taxes?

Yes, significantly. The US and Australia have a Social Security totalization agreement, so self-employed Americans in Australia usually avoid paying into both systems. New Zealand has no such agreement, so a self-employed American there can owe the full 15.3% US self-employment tax on top of NZ tax. For freelancers and business owners, this is a real factor in the choice.