This is an unusual situation and I haven't been able to find an answer. Perhaps someone else has dealt with this. I have a client who worked for the British Embassy in the United States until a few months ago. She is a dual U.S./British citizen. The income she earned there was not taxed by the U.S. Government. She contributed to a 401(k) plan (not recommended by me) while she was employed. She is interested in rolling her British Embassy 401(k), currently at ING, to an IRA. My question is how the 401(k) account is viewed for tax purposes - is it an after-tax account (like a Roth) or a before-tax account? (It's really a no-tax account, if there is such a thing.) My concern is that I don't want to turn a tax-free account into a taxable account in the process of rolling it over. I suspect it needs to be rolled into a traditional IRA but I'm just not sure. The client, by the way, has asked human resources about this, but they didn't seem to have the answer either. Thanks for any insight/comments.