Question was asked in one of the Aussie expat groups on Facebook and I thought it was worth posting my answer here as well
lol if reading this article doesn't infuriate you.....then you don't understand the question.
US Pension transfer and withdrawal to Australia. 401(k), IRA, Roth IRA, 403(a), 403(b). Tax minimization - https://txmchartered.com/us-pension-transfers-to-australia-401k-ira-403a-403b-australian-tax-implications
My answer is lol....or John tells the ATO to GAGF and withdraws the entire sum BEFORE arriving in Australia and doesn't end up owing the ATO $83,632 on top of what he already paid the IRS.