The only way to avoid the otherwise mandatory 20% tax withholding is to request a direct rollover to a traditional IRA and then take a distribution from the traditional IRA. There is no mandatory withholding on a direct rollover and tax withholding on a traditional IRA distribution can normally be declined. However, if she is a foreign person at the time of the distribution from the traditional IRA, there might be 30% mandatory tax withholding: https://www.irs.gov/retirement-plans/plan-distributions-to-foreign-persons-require-withholding
