non resident alien presently working in the U.S. – is moving home to Australia
She is due to move back late early next year (2019)

Question:
Can her 401k be transferred (tax free) to the Australian 401k (e.g. superannuitation)?

If not are there any available strategies moving the account tax free to Australia?
IF not, assuming a distribution is taken would she be subject to U.S. income tax + penalty (she is under 59.5)

Thank you