Money and Tax

Reading Order

1. RNOR Explained: Who Qualifies and How Long It Lasts

   RNOR is not an automatic two-year exemption. Review the residence tests, preceding-year history, special visitor rules and income-scope limits before your return.

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2. India-US DTAA Tie-Breaker Rules

   When both India and the US claim you as resident in the move year, Article 4(2) of the India-US DTAA sets the order. Walk the hierarchy with worked examples.

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3. DTAA explained: How NRIs actually claim relief from double taxation

   A plain-English walk-through of how India's Double Taxation Avoidance Agreements work in practice — credit vs exemption method, Form 67, Rule 128, and what NRIs and returnees need to file.

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4. RNOR Capital Gains Harvesting Window

   Why a real RNOR-window sale and repurchase of foreign holdings can approximate a cost-basis reset, where it breaks, and the Section 5 and 6(6) limits.

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5. RSU Cost Basis Step-Up Myth for NRIs

   Indian law does not reset the cost basis of vested US RSUs on return. RNOR narrows what India taxes; it does not rewrite the acquisition price. The actual rule.

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6. Indian Mutual Fund Tax for Returnees

   Finance (No. 2) Act 2024 rewrote STCG, LTCG, and Section 50AA for Indian mutual funds. For US-person returnees, three rule sets touch the same redemption.

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7. When an NRI Pays Zero India Tax on Mutual Fund Gains: The DTAA Article 13 Carve-Outs Explained

   Some NRIs redeem Indian equity mutual fund units and pay no India tax on the gain. The mechanism is not a loophole. It is Section 90 of the Income-tax Act reading down to Article 13 of the applicable DTAA, together with grandfathering rules that still matter.

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8. India-US Gift Tax for Returnees

   India taxes the recipient under Section 56(2)(x); the US taxes the donor and adds Form 3520 on foreign-person receipts. Map both rule sets for a returnee.

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9. Gifting Overseas Property After Moving Back to India: What Section 6(4) FEMA and the OI Rules 2022 Actually Say

   The condo in Jersey City, the flat in Dubai, the semi-detached in Reading, bought while you were an NRI, still standing while you settle back in India. What happens when you want to gift it, and to whom you can gift it, is governed by Section 6(4) of FEMA read with the OI Rules, Regulations, and Directions of 2022, not by the LRS.

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10. UK to India: Split Year, RNOR and Capital Gains

    Review the UK's residence and split-year rules alongside India's RNOR income scope. Share-sale timing, temporary non-residence and treaty limits all need separate checks.

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11. Buying property from an NRI seller: Section 195 TDS, the TAN trap, and the Section 197 certificate

    When an Indian resident buys immovable property from a non-resident seller, the TDS provision is Section 195 of the Income-tax Act, not the 1 percent Section 194-IA that applies to resident-to-resident sales. The buyer needs a TAN and files Form 27Q. Tax is deducted on sums chargeable under the Act; in the absence of an Assessing Officer determination under Section 195(2) or a Section 197 lower-deduction certificate, buyers commonly deduct conservatively on the gross consideration.

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12. How to File Form 10F Online Without a PAN

    Filing Form 10F on the income tax portal without a PAN - the non-resident registration route, documents required, and the errors that get filings rejected.

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13. India-Thailand DTAA Has No FTS Article

    The India-Thailand tax treaty has no specific Fees for Technical Services article. Recent ITAT authority — East West Seeds (ITAT Pune, 2025) following Bangkok Glass (Madras HC) and Denso Thailand (Delhi ITAT) — has rejected the default Article 22 bucket for business-related FTS and routed the analysis through Article 7 read with Permanent Establishment. Walk the structure with primary sources.

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