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Indian tax and compliance, from the USA

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The United States taxes its citizens and green card holders on worldwide income wherever they live. No other major country does this. It means an Indian-origin US citizen has to report Indian rent, Indian interest and Indian capital gains on a US return every year, and it does not stop when they move back to India.

The reporting sits on top of the tax. Indian bank accounts, demat holdings, insurance policies with a cash value and any signature authority over a family account can trigger FBAR and FATCA disclosure. The penalties there attach to the failure to report, not to any tax owed, which is why people who owe nothing still get hurt.

The India–US treaty prevents the same income being taxed twice, but the credit has to be claimed correctly on both sides, and the two tax years do not line up — India runs April to March, the US runs the calendar year. That mismatch alone causes more credit failures than the rules do.

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Working out what India still expects from you?

Two fields. We come back with what applies to your residency position and what it costs — and we work Indian hours, so allow for the time difference.

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Before anything else

Who holds which licence

Tax Station — India

Anything under the Income-tax Act, FEMA or the Companies Act. Your Indian return, treaty relief, remittance certificates, and an Indian company if you need one. Our work, our fee, published on each service page.

Anything filed in the USA

Your USA return, and anything filed with the authorities there, needs an adviser licensed in the USA. We do not hold that licence and will not pretend to. What we will do is make sure the Indian position we take fits the one they take, and speak to them directly where the two have to line up.

We say this up front because it decides who is answerable if something goes wrong. One point of contact, two firms, and you should know which is which before you engage either.

Where it goes wrong

What catches people in the USA

01

Indian mutual funds are PFICs

A US person holding Indian mutual funds almost certainly holds passive foreign investment companies. The default US treatment is punitive — an interest charge on deferred gains and no capital gains rate — and reporting each fund on Form 8621 is separate from the tax. SIPs bought casually during a visit to India create years of this quietly.

02

NRE interest is exempt in India and fully taxable in the US

The exemption is a feature of Indian law, not of the treaty. To the US it is ordinary interest income, and because no Indian tax was paid there is no foreign tax credit to offset it. People assume tax-free means tax-free everywhere.

03

Tax years that do not align

Indian tax paid on income for April to March has to be matched against US tax on a January to December year. Claiming the credit in the wrong US year, or claiming Indian tax before it is actually paid, is the most common reason a foreign tax credit is disallowed on review.

04

Selling Indian property while a US person

The buyer withholds under section 195 in India on the full consideration, the gain is computed under Indian rules with indexation, and the US then recomputes the same gain under its own rules with no indexation at all. The two numbers differ, and the credit only covers what overlaps.

05

Schedule FA when you return

Becoming an Indian resident again brings US accounts, 401(k) balances, brokerage holdings and stock plans into Schedule FA of the Indian return. The disclosure obligation arrives before most people have thought about the tax, and the penalty regime for undisclosed foreign assets in India is severe.

06

RNOR is the window that makes the move affordable

Someone returning to India after years in the US usually qualifies as Resident but Not Ordinarily Resident for two or three years, during which US income stays outside the Indian net. Identifying it in the first return is what makes the transition work; missing it costs real money.

Before you act on this

Residency tests, treaty relief and reporting thresholds change on both sides of the border, and the two countries' tax years rarely align. This explains the position in general terms and is not advice on your facts. Check the current rule, or ask us, before you act on it.

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