The Dual Tax Labyrinth

A Visual Guide for U.S. Citizens with Indian Income

One Income, Two Tax Systems

As a U.S. citizen, you're taxed on worldwide income. As a Non-Resident Indian (NRI), you're taxed on Indian-sourced income. This creates an overlap that you must navigate correctly.

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U.S. Citizenship-Based Taxation

The U.S. taxes you on every dollar you earn, anywhere in the world, simply because you are a citizen. Your physical location doesn't matter.

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Indian Source-Based Taxation

India taxes you only on income that originates from an Indian source, such as rent from an Indian property or interest from an Indian bank.

It's Not Just About Tax—It's About Reporting

Failure to report your foreign assets can lead to severe penalties, even if you don't owe any tax. The U.S. and India automatically exchange financial information, making compliance essential.

FBAR & FATCA: Know the Difference

These are two separate reports with different rules, thresholds, and penalties. You may need to file one, both, or neither.

FBAR (FinCEN 114)

Filed if the total value of all your foreign accounts exceeds $10,000 for even a single day.

FATCA (Form 8938)

Filed with your tax return if your foreign assets exceed higher thresholds (e.g., $50,000 for singles living in the U.S.).

The Single Most Important Threshold

Remember this number:

$10,000

If the combined peak balance of ALL your Indian accounts hits this, you MUST file an FBAR. This rule trips up many people.

The "Tax-Free" Trap

Indian banks advertise NRE accounts as "tax-free," which is true in India. But for a U.S. citizen, this creates a tax trap because no Indian tax means no Foreign Tax Credit to use against your U.S. tax bill.

NRO Account Interest

Tax is paid in India, creating a credit to offset U.S. tax. This prevents double taxation.

NRE Account Interest

No tax is paid in India, so there is no credit. You pay the full tax in the U.S.

The Capital Gains Exemption Mismatch

This is the most significant financial trap. When you sell a property in India, you can avoid Indian tax by reinvesting the gains. But the U.S. doesn't recognize this exemption, leading to a surprise tax bill.

Visualizing a $200,000 Property Gain

Compare two scenarios: paying the 20% tax in India versus using an Indian exemption to pay 0% tax in India. The outcome might surprise you.

Key Takeaway: Paying tax in India can result in higher net proceeds because the Foreign Tax Credit drastically reduces your U.S. tax bill.

Your Annual Compliance Workflow

Follow this order to stay compliant and correctly calculate your credits. Finalizing your Indian taxes first is the key to an accurate U.S. return.

1

File Indian ITR

Finalize your Indian tax liability and pay any tax due. This is your proof for the Foreign Tax Credit. (Due: July 31)

2

File FBAR

Separately file FinCEN Form 114 online if you meet the $10,000 threshold. Do not file this with your tax return. (Due: Oct 15)

3

File U.S. Tax Return

Report worldwide income on Form 1040. Attach Form 8938 (FATCA) if needed and Form 1116 to claim your Foreign Tax Credit. (Due: Oct 15 w/ extension)