The situation
Where the client started.
Senior tech professional returning mid-year with USD 1.2M in US brokerage and a 401(k).
Problem
What was at stake.
- Client wanted to return in May; that triggered residency same FY and would have collapsed RNOR to a single year.
- 401(k) and brokerage interest/dividends were about to become India-taxable on a worldwide basis.
- No plan for Form 67 / DTAA layering with the residual US filing.
Approach
How we worked it.
- Re-modelled the 182-day and 60+365 day tests across two FYs.
- Shifted physical move to early August, preserving NRI status in the year of move and triggering RNOR for FY+1 and FY+2.
- Pre-filed Schedule FA structure with the 401(k), HSA and brokerage broken out asset-by-asset.
- Set up Form 67 process for foreign tax credit on US dividends post-RNOR.
Outcome
What changed.
- Two clean RNOR years: US investment income not taxed in India.
- USD 38k in pre-empted India tax, computed against the May-return baseline.
- Clean Schedule FA on first resident return — no notices.
Takeaway
The principle behind it.
When you land matters more than where you land. The RNOR window is the single biggest lever for a US returnee — and it's set by your travel diary, not your CA.