Many people who built up an IRA or 401(k) while working in the U.S. keep those accounts after moving back to Japan. Once you reach a certain age, these accounts come with required minimum distributions (RMDs): a minimum amount you must withdraw every year.
This article is for people living in Japan who hold a traditional IRA or 401(k), including former expats who have returned and U.S. citizens or green card holders living in Japan. It covers when RMDs start, the deadlines and penalties, how Roth accounts are treated, U.S. withholding and the U.S.–Japan tax treaty, and how Japan taxes the payments.
If you were born in 1953, you turn 73 in 2026, which makes 2026 your first RMD year. If your RMDs have already started, your 2026 RMD is due December 31. Now is the time to check.
The short answer
- RMDs generally start in the year you turn 73 if you were born in 1951 through 1959, or 75 if you were born in 1960 or later.
- Only your first RMD can be delayed until April 1 of the following year, but then you take two RMDs that year. Every later RMD is due by December 31.
- A shortfall triggers a 25% excise tax. It drops to 10% if you correct it within the correction window, and you can request a waiver on Form 5329 for a reasonable error.
- Roth IRAs and designated Roth accounts in 401(k) and 403(b) plans have no RMDs while the owner is alive.
- Distributions to a nonresident alien living in Japan face 30% withholding by default. Under the U.S.–Japan treaty, pensions are taxable only in the country of residence, and you claim it on Form W-8BEN. U.S. citizens remain taxable by the U.S.
What RMDs are, and when they start
RMDs make you draw down tax-deferred retirement savings once you reach a certain age. They apply to traditional IRAs, SEP IRAs, SIMPLE IRAs, and most retirement plans, such as 401(k), 403(b), and 457(b) plans. Distributions are included in taxable income except for any part that was taxed before (your basis). You can always take more than the minimum.
The starting age depends on your birth year under the SECURE 2.0 changes. Proposed regulations published in 2024 provide that the applicable age for someone born in 1959 is 73.
| Year of birth | RMD age | First RMD deadline |
|---|---|---|
| 1951 to 1959 | 73 | April 1 of the year after you turn 73 |
| 1960 or later | 75 | April 1 of the year after you turn 75 |
For workplace plans such as a 401(k), if the plan allows it, you can delay RMDs until you actually retire, unless you are a 5% owner. That exception applies to employer plans, not IRAs. The IRS RMD guidance does not describe any exception for account owners who live abroad, so plan on the same ages and deadlines while living in Japan.
Deadlines: the first-year April 1 rule and December 31
Your first RMD is for the year you reach 73 (or 75), but you can delay that first one until April 1 of the following year. In the IRS example, someone who reached 73 in 2024 must take the first RMD by April 1, 2025, and the second by December 31, 2025.
- Born in 1953 (age 73 in 2026): the 2026 RMD is due by April 1, 2027, and the 2027 RMD by December 31, 2027.
- Born in 1952 (age 73 in 2025): the 2025 deadline (April 1, 2026) has passed, and the 2026 RMD is due by December 31, 2026.
Delaying the first RMD means two distributions in one year, which raises that year’s income. If you live in Japan, your Japanese income for that year rises too, so compare the tax in both countries before deciding.
Each account’s RMD equals its balance on December 31 of the prior year divided by a life expectancy factor (distribution period). Most owners use the Uniform Lifetime Table, where the factor is 26.5 at 73, 25.5 at 74, and 24.6 at 75. If your spouse is your sole beneficiary and more than 10 years younger, you use the Joint and Last Survivor Table instead.
If you have several IRAs, calculate the RMD for each, then withdraw the total from any one or more of them. RMDs from 401(k) and 457(b) plans must be taken separately from each plan. An RMD cannot be rolled over into another IRA or plan.
Penalties: the 25% excise tax, the 10% reduction, and waivers
If you do not withdraw the full RMD on time, the shortfall is subject to a 25% excise tax, reported on Form 5329. The rate drops to 10% if, during the correction window, you take the missed amount and file a return reflecting the tax. The correction window ends on the earliest of:
- the date the IRS mails a notice of deficiency for the tax,
- the date the tax is assessed, or
- the last day of the second taxable year that begins after the year the tax is imposed.
If the shortfall was due to reasonable error and you are taking reasonable steps to fix it, you can request a waiver by attaching an explanation to Form 5329 and writing “RC” with the waived amount, as the form instructions describe. Mail from a U.S. custodian can be easy to miss in Japan, so if you discover a missed RMD, take the distribution first, then work out the filing.
Roth IRAs and Roth 401(k)s
Roth IRAs and designated Roth accounts in 401(k) and 403(b) plans do not require withdrawals while the owner is alive. Beneficiaries who inherit them must follow the RMD rules.
Roth distributions can be tax-free in the U.S., but how Japan treats a Roth distribution to a Japanese resident is a separate question to confirm. For the basics of traditional versus Roth accounts, see our U.S. retirement accounts guide.
U.S. withholding and the U.S.–Japan tax treaty when you live in Japan
How the U.S. treats your RMD depends on your U.S. tax status.
| Your U.S. status | U.S. withholding and tax | What to do |
|---|---|---|
| Japanese national, U.S. nonresident alien (e.g., a returned expat) | 30% withholding by default; may be reduced under the treaty | Give the custodian Form W-8BEN claiming treaty benefits |
| U.S. citizen | Taxed by the U.S. (treaty saving clause) | Japan also taxes you as a resident, so double tax relief matters |
| Green card holder living in Japan | Generally treated as a U.S. resident | Treaty residence and green card consequences need a case-by-case review |
When a U.S. payer makes a plan distribution to a foreign person, it generally must withhold 30%. To apply a lower rate, the payer needs valid documentation such as Form W-8BEN; without it, the payer cannot reduce the 30%. The payment is reported on Form 1042-S.
Article 17(1) of the U.S.–Japan income tax treaty provides that pensions and other similar remuneration, including social security payments, beneficially owned by a resident of one country are taxable only in that country. The IRS Tax Treaty Table 1 lists a 0% U.S. rate for pensions and annuities paid to residents of Japan, citing Article 17(1). To claim it, you give the custodian a W-8BEN certifying Japanese residence. Lump-sum payouts and reclaiming over-withheld tax by filing Form 1040-NR are covered in our article on withdrawing a 401(k) or IRA after returning to Japan and our treaty pension guide.
Article 1(4), the saving clause, provides that the treaty does not affect U.S. taxation of its residents and citizens. A U.S. citizen living in Japan therefore pays U.S. tax on RMDs as ordinary income.
If you are taxed by the U.S. (for example, a U.S. citizen) and are 70½ or older, a qualified charitable distribution (QCD) paid directly from your IRA to a qualified charity can satisfy all or part of your RMD while being excluded from income. The 2026 QCD limit is $111,000. It must go to an eligible U.S. charity, not a Japanese one.
How Japan taxes your RMD
A Japanese resident (other than a non-permanent resident) is taxed on all income, wherever it arises. Because the treaty gives Japan, as the country of residence, the right to tax pensions, RMDs received while living in Japan generally belong on your Japanese tax return. A non-permanent resident (no Japanese nationality and five years or less of residence in Japan within the past 10 years) is taxed on foreign-source income only to the extent it is paid in or remitted to Japan.
How Japan classifies an IRA or 401(k) payment (public-pension-type miscellaneous income, other miscellaneous income, occasional income, and so on) is not spelled out for IRAs or 401(k)s by name in the National Tax Agency’s Tax Answers, and it can depend on whether you take periodic or lump-sum payments and on the plan. The NTA treats pensions from foreign-law systems similar to Japanese social insurance as “public pensions, etc.” and says that if you receive public pensions not subject to Japanese withholding, you must file a return regardless of the amount; the filing exemption for small pension income does not apply.
Dollar payments are generally converted to yen at the TTM (telegraphic transfer middle) rate on the date received. If you paid U.S. tax (for example, as a U.S. citizen), Japan’s foreign tax credit may let you offset it up to a limit. For filing your U.S. return from Japan, see our guide to filing from Japan.
Worked example: turning 73 in 2026
Example: B was born in 1953, is a Japanese national living in Japan, and is a U.S. nonresident alien. B’s traditional IRA held $300,000 on December 31, 2025, and B has no other retirement accounts.
- The 2026 RMD is $300,000 ÷ 26.5 (the age-73 factor) = about $11,321.
- If B delays it to April 1, 2027, and the December 31, 2026 balance is $310,000, the 2027 RMD is $310,000 ÷ 25.5 (the age-74 factor) = about $12,157, so B withdraws about $23,478 in 2027.
- Without a W-8BEN, 30% withholding on the 2026 RMD alone is $11,321 × 30% = about $3,396.
- If B skips the 2026 RMD entirely, the excise tax is $11,321 × 25% = about $2,830, or $11,321 × 10% = about $1,132 if corrected within the correction window.
In Japan, B reports each RMD as income for the year received, converted at that day’s TTM rate.
FAQ
Do I still have to take RMDs if I live in Japan?
The IRS RMD guidance does not describe an exception for owners who live abroad. If you hold a traditional IRA or 401(k), plan on the same starting age and deadlines.
What is the downside of delaying my first RMD to April 1?
You take two RMDs in the following year, which increases that year’s income, in both the U.S. and Japan if you live there.
Do Roth IRAs have RMDs?
Not while the owner is alive, and the same is true for designated Roth accounts in 401(k) and 403(b) plans. Beneficiaries who inherit them are subject to RMD rules.
What if I missed the deadline?
The shortfall is subject to a 25% excise tax, reduced to 10% if corrected within the correction window. If it was a reasonable error, you can request a waiver on Form 5329.
I have two 401(k)s. Can I take the total from one?
No. 401(k) and 457(b) RMDs must be taken separately from each plan. Only IRA RMDs can be totaled and taken from any one or more IRAs.
At CLT NY INC., an IRS Enrolled Agent helps clients living in Japan review their RMDs, file Form 1040 or 1040-NR, and claim treaty benefits with Form W-8BEN, in Japanese or English. Contact us.
Related articles
- US Retirement Accounts Tax Guide: Understanding 401k & IRA, Traditional vs. Roth, Early Withdrawal Penalties, and Tax Implications for Repatriates to Japan
- Withdrawing a 401(k) or IRA After Returning to Japan: 30% Withholding and Relief Under the US-Japan Tax Treaty
- US-Japan Pension Taxation and Tax Treaty Articles 17 & 18: A Comprehensive Guide to the “Taxable Only in Japan” Rule for US Pensions (401k/IRA) for Japanese Residents and Dual Taxation Avoidance
- Pre-Departure Checklist: What to Confirm Before Closing Your US Bank, Brokerage, and 401(k) Accounts
- The Definitive Guide to Filing US Tax Returns (1040/1040NR) from Japan After Repatriation: Procedures, Payment, and Refund Methods
Sources: IRS, Retirement topics: Required minimum distributions (RMDs); IRS, Retirement plan and IRA required minimum distributions FAQs; Federal Register, Required Minimum Distributions (July 19, 2024); Federal Register, Updated Life Expectancy and Distribution Period Tables (Nov. 12, 2020); IRS Publication 590-B; IRS Instructions for Form 5329; IRS, Plan distributions to foreign persons require withholding; IRS, Claiming tax treaty benefits; U.S.–Japan Income Tax Convention (2003); IRS Tax Treaty Table 1; IRS, Retirement plans FAQs regarding IRAs distributions; IRS Notice 2025-67; National Tax Agency of Japan, Tax Answer No. 2010; NTA Tax Answer No. 1600; NTA Q&A on pension income not subject to withholding; NTA e-filing guide on pensions from abroad; NTA Tax Answer No. 1240. Information as of October 2026. This article provides general information and is not individual tax advice.
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