IRS simplifies retirement-plan rollovers: what the new SECURE 2.0 guidance means for cross-border savers

Summary

On August 12, 2026, the Department of the Treasury and the IRS released guidance designed to simplify and standardize the process of rolling over money between retirement plans and individual retirement accounts. Under IR-2026-91, the agencies issued sample forms for direct rollovers to or from a retirement plan, as required by Section 324 of the SECURE 2.0 Act. The Journal of Accountancy notes that use of the sample forms and the proposed rollover procedures is optional for plan sponsors.

Direct rollovers — moving funds straight from one retirement account to another without the money passing through the taxpayer's hands — are generally the cleanest way to move retirement savings from a tax perspective. Standardized forms aim to reduce the administrative friction and documentation errors that often accompany these transfers.

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Our Take

For Canadians holding U.S. retirement accounts — a 401(k) from a U.S. employer or an IRA built up during years working stateside — rollovers carry an extra layer of complexity: the transfer must be handled correctly under U.S. rules, and the movement of funds can also raise questions on the Canadian side of the border, where U.S. retirement plans receive distinct treatment under the Canada–U.S. tax treaty.

Simpler, more standardized rollover documentation is welcome news for cross-border filers, because errors in these transactions can be costly and hard to unwind. That said, optional forms mean plan sponsors may still follow their own procedures, so the practical experience can vary from one institution to another. Anyone moving retirement money between U.S. accounts — or consolidating accounts before returning to Canada — should confirm the rollover is a direct, trustee-to-trustee transfer and consult a CPA who understands both the U.S. rules and the treaty treatment of U.S. retirement savings.

Disclaimer: This article is general information only and does not constitute tax advice; it should not substitute professional tax counsel. Please consult a licensed CPA for advice specific to your situation.