Does Australia or the US tax my Sydney salary first?
For employment income the country where the work is physically done normally has the first claim, and the other gives relief for tax properly paid there. So salary earned for work performed in Australia is generally taxed there first, with the US return computed afterwards and relief claimed on it. The order matters practically as well as technically: relief depends on tax finally determined on the other side, and the two countries close their tax years on different dates, so the tax paid has to be mapped onto the right year before any credit can be computed.
Is my superannuation taxed by the US while it stays in the fund?
That depends entirely on how the fund is characterised, and it is not safe to assume it is treated the way a domestic US plan is. Superannuation is a creature of Australian law, and the US system does not automatically extend to it the deferral it gives its own retirement arrangements. Depending on characterisation, employer contributions and earnings inside the fund can fall into the US computation in the years they arise, which is out of step with when Australia taxes them. The characterisation is settled on the fund's actual terms and then followed consistently.
Will I get US credit for the Australian tax my employer withheld?
Relief is generally available for foreign tax properly paid on income the other country has the first claim to, but three things decide whether a claim survives scrutiny. Whether the income is of a class Australia was entitled to tax first. Whether the amount claimed is tax finally determined rather than tax withheld during the year. And whether it is matched to the right year on the US side, given that the Australian year does not close on the same date. Withholding shown on a payslip is a starting point, not the claim itself.
I am Australian and moving to the US, does Australia tax me on exit?
Leaving raises its own questions before the US ones begin. Ceasing Australian residence has consequences under Australian rules for the assets you hold and for the year of departure, and those are dealt with on the Australian side in their own right. Deciding the exit position first is what makes the first US year computable, because it fixes the date from which income belongs to the new country and establishes the basis of anything you carry across. Working in the other order is how people end up amending returns in both countries.
Why do my Australian and US tax years not line up?
They close on different dates, which is a mechanical problem rather than a legal one, and it affects every relief claim in this corridor. Income and tax recorded against one country's year have to be re-cut to fit the other's before relief is computed, and payroll summaries are issued to the local year, not the foreign one. In practice that means building a monthly or workday schedule of earnings and tax once and using it for both returns, rather than reconciling two annual summaries that were never designed to agree.
Does a self-managed super fund create US obligations for me?
It raises the characterisation question in its sharpest form, because a self-managed fund is both a retirement arrangement and an entity you control. How it is characterised under US rules decides whether its income is attributed to you as it arises, and it drives fund reporting that applies whether or not any tax results. The analysis turns on the deed, the membership and trusteeship, and how the fund is actually administered, rather than on the label. Settle it before the first US return and follow the same position afterwards.
How would a foreign tax authority know I am resident there?
Mostly from information you or your bank already provided. Account-opening forms ask you to self-certify tax residence, and that certification is reported between authorities under the Common Reporting Standard or, for US accounts, under the FATCA framework. Beyond that: employer and payroll filings, property registries, immigration records and the tax filings of anyone who paid you. The realistic planning assumption is that the data arrives. See FATCA and information reporting.
How do families with assets in two countries handle inheritance?
With paperwork built for both systems rather than one. In practice that means wills that work where each asset actually sits, an executor with authority a foreign bank or land registry will accept, clearance certificates before the estate distributes so the executor is not left personally exposed, and an estate tax exposure calculation done while the person is alive and can still act on it. Doing it afterwards costs more and forecloses most of the options. See cross-border wills and trusts.
