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/ Dual-Tax India-US Specialist · Updated 2026-10-22

CA for NRI / US Citizen Dual Tax India-US Coordinated, DTAA + Form 1040 + Indian ITR integrated.

NRI / US green card holder / US citizen with India exposure faces dual-tax complexity across Indian ITR + Form 1040 US + FBAR + Form 8938. India-US DTAA + Foreign Tax Credit prevent double tax but require coordinated execution. BQP coordinates India-side compliance with US CPA / tax advisor for integrated single-year filing. Here's the complete framework.

DC

Written by CA Durgesh Chavda

Chartered Accountant (ICAI) · Founder, Bharat Quantum Prospera · US incorporation, India-US DTAA, FEMA ODI, NRI taxation, cross-border structuring · LinkedIn

/ The dual-tax picture

Who pays what.

  • US tax person (citizen + green card holder): worldwide income taxable in US. Form 1040 + Form 1116 (FTC) + FBAR + Form 8938 (FATCA).
  • Indian tax resident (Section 6): worldwide income taxable in India. Indian ITR + Form 10F + TRC for DTAA relief.
  • Dual tax residence: possible when physically present in both for parts of year. Article 4 India-US DTAA tie-breaker: permanent home / centre of vital interests / habitual abode / citizenship.
  • NRI (Indian non-resident): only India-source income taxable in India. US-source income not Indian-taxable.
  • RNOR (returning NRI): 2-3 year transition status. Foreign-source investment income exempt in India.

/ Coordinated engagement workflow

How we work with US CPA.

  1. Residence status determination both sides (Section 6 India + IRS Section 7701(b) US).
  2. Income inventory: Indian salary / business + US salary / business + capital gains + rental + dividend + interest in both countries.
  3. DTAA position analysis: treaty rate on each income type.
  4. Section 195 TDS deducted on Indian income - verify treaty rate claimed via Form 10F + TRC.
  5. Form 1116 US FTC: credit for Indian taxes paid.
  6. Section 90 India FTC: credit for US taxes paid on US-source income.
  7. FBAR: all Indian financial accounts above USD 10K aggregate.
  8. Form 8938: Indian financial assets above USD 50K/100K threshold.
  9. Section 877A exit tax if giving up green card / US citizenship.
  10. India-US estate tax planning integration for US-tax-person with Indian assets.

/ Common scenarios we handle

Where coordination matters.

  • Green card holder returning to India - RNOR optimisation + US tax maintenance.
  • US citizen with Indian rental property - dual-reporting + FTC.
  • NRI selling Indian property - LDC + Section 54 + US capital gain reporting.
  • Indian mutual fund held by US tax person - PFIC complexity + Indian LTCG.
  • Indian ESOP exercise by green card holder - perquisite tax + Section 192 TDS + US W-2 reporting.
  • Indian NRE / NRO interest - exempt in India but US-taxable.
  • Section 877A exit tax planning before green card surrender.
  • Inheritance of Indian property by US tax person - US estate tax + Indian mutation.

Last updated: 2026-10-22.

/ Ready when you are

NRI / US green card holder / US citizen with India exposure?

Dual-tax coordinated engagement: India + US + DTAA + FTC + FBAR + Form 8938. BQP + your US CPA integration.

FAQ

Common questions, answered.

Do I pay double tax on Indian income as a US citizen / green card holder?
No - India-US DTAA + Foreign Tax Credit (FTC) prevent double tax. Pay Indian tax on India-source income (reduced to treaty rate via TRC + Form 10F); claim FTC in US Form 1040 Form 1116 for Indian taxes paid. Net: same aggregate tax as higher of two tax rates on each income type. But reporting + documentation complexity across both countries.
How is Indian mutual fund taxed for US tax person?
Indian LTCG 12.5% post Finance Act 2024 (STCG at applicable rate). US treats Indian mutual fund as PFIC (Passive Foreign Investment Company) - complex taxation under IRC Section 1291-1298. Options: QEF election (requires annual information from fund), Mark-to-Market election (annual gain recognition), default PFIC rules (highest rate + interest charge). Specialised cross-border tax advice essential.
What's Section 877A exit tax when giving up green card?
Covered expatriate = LPR who (a) 5-year avg tax > USD 206,000 (2026), OR (b) net worth > USD 2 million, OR (c) fails 5-year certification. Mark-to-market: all worldwide assets deemed sold at FMV on day before expatriation. Deemed gain taxed with USD 866,000 exclusion (2026). Specific rules for IRA / 401k / deferred compensation. Pre-planning essential.
Can BQP coordinate with my US CPA?
Yes - standard engagement model. BQP handles India-side (Indian ITR + Form 10F + TRC + Section 195 TDS + FEMA + Indian capital gain + property / investment tax) + co-ordinates with your US CPA for Form 1040 + Form 1116 FTC + FBAR + Form 8938 + Section 877A if applicable. Integrated single-year filing across both countries.
What's the biggest coordination challenge NRIs face?
FY difference: Indian FY April-March; US tax year January-December. Income earned in Jan-Mar is in Indian FY X but US tax year Y - requires careful allocation. FTC calculation under Form 1116 limits based on US tax year. Timing of DTAA treaty rate claim matters. BQP handles this allocation + co-ordination with US CPA.
Is BQP a good fit for NRI / US dual-tax clients?
Yes - specialist practice. Residence status (Section 6 + IRS 7701(b)) + DTAA + FTC + FBAR + Form 8938 + Section 877A + estate planning integration. Co-ordinated with US CPA. For returning green card holders / dual-tax clients / US citizens with India exposure. WhatsApp +91 78018 87130.