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The Fiqh Council of North America has ruled the following on this topic:
If one’s due Zakat payment on such an account exceeds what one has the means to pay from one’s available wealth, then one pays on his or her due Zakat what one can, records the remaining deficit as an owed Zakat debt, and pays that Zakat debt (owed to Allah) as soon as one has the means to pay it. This opinion, moreover, holds that one may pay this Zakat debt off in increments. However, as soon as one gains absolute and undivided authority over one’s account — to cash out at one’s discretion — any outstanding Zakat immediately comes due and one must pay it in full without delay.
Example:
One has a 401(k) account balance of $300,000 on which one wants to pay Zakat. One will not, however, have full and free access to one’s account for two years. One calculates that after penalty, fees, and taxes, one can withdraw $180,000. This exceeds nisab. One calculates a Zakat payment of 2.5% from this amount, which comes to $4,500 owed as one’s Zakat at one’s Zakat Due Date. One only has enough funds to pay $1,500 of One’s Zakat at one’s Zakat due date. One pays this amount in Zakat and records one’s outstanding Zakat balance as $3,000 to be paid once available.