A US-based NRI returning permanently to India was unaware that incorrect residency planning would expose his global income to Indian tax. PGA & Co. structured his transition through RNOR status, saving significant tax in the year of return.
â ï¸ The Challenge
Client was returning to India after 12 years in the USA. Had foreign income of ~₹3.2 Cr including salary (partial year), rental income from two US properties, and ESOP vesting. Was about to be treated as resident with unlimited global income taxability.
ð¡ Our Solution
We established RNOR (Resident but Not Ordinarily Resident) status through careful day-count planning. Structured the return date to maximise the RNOR window. Filed Form 67 for DTAA treaty relief on US taxes paid. Advised on repatriation of funds under LRS limits.
â Results Achieved
- RNOR status secured for 2 financial years
- Foreign income protected from Indian tax during RNOR window
- Estimated tax saving of ₹18 Lakh
- Full repatriation of funds completed compliantly
* Client identities and specific financial figures may have been modified to preserve confidentiality. All case studies represent real engagement types handled by PGA & Co.
Have a similar situation?
Our experts are ready to help you find the right solution.