Immigration status

Planned move year

Married?

Move age

Kids?

RNOR iNRI — Non-Resident Indian: not yet tax-resident; foreign income fully exempt.
RNOR — Resident but Not Ordinarily Resident: a transitional window (typically 2 yrs) where foreign income stays exempt — the best time to liquidate US assets.
ROR — Resident & Ordinarily Resident: fully taxable on worldwide income.

Expected MAGI (USD) iMAGI — Modified Adjusted Gross Income
Your gross income before most deductions: W-2 wages, self-employment, dividends, rental income. Used to determine your US tax bracket. Capital gains and retirement withdrawals you enter below are added on top of this number.

Spouse details

Status

Age

Expected MAGI (USD) iMAGI — Modified Adjusted Gross Income
Spouse's gross income before most deductions: W-2 wages, self-employment, dividends, rental income. Combined with primary MAGI to determine the joint US tax bracket.

RNOR window

Number of children

529 / UTMA balances and citizenship details live in the Estimation Room →

Brokerage / Trading Accounts — inputs

Total value iEnter the combined total across all your brokerage & trading accounts — Robinhood, Fidelity, Schwab, E*TRADE, etc. Include stocks, ETFs, mutual funds, and any taxable investment accounts (not retirement accounts like 401k/IRA).

Est. long-term gain optional iIf left at $0, the tool assumes you have no unrealized gains (i.e. your cost basis equals your current value). This means zero capital gains tax on liquidation — effectively modeling a break-even or loss position. Enter your actual gains for a realistic tax estimate.

Est. short-term gain optional iSame as long-term — leaving this at $0 assumes no short-term gains. Short-term gains (held <1 year) are taxed at ordinary income rates, which are significantly higher than long-term capital gains rates.

Spouse

Spouse brokerage value

Spouse LT gain optional

Spouse ST gain optional

529 / Kids — per-child accounts

💡 US Citizen kid planning: UTMA/custodial accounts subject to kiddie tax (unearned income >$2,500 taxed at parent's rate until age 19/24). 529 plans usable at select Indian universities — verify eligible institutions. Gifts from NRI parent to US citizen child >$18k/yr require Form 3520 reporting (no tax owed). US citizen children inherit Indian assets tax-free (India has no inheritance tax). When child moves to India, their own NRA/residency questions apply. Social Security credits earned by parent may benefit US citizen children long-term.

📚 Reference — India accounts & Ireland-domiciled funds

🏦 Indian accounts for returnees

Account	Best for	Interest taxable?	Repatriation
NRE	Foreign income remitted to India	Tax-free (NRI/RNOR)	Unrestricted
NRO	India-sourced income (rent, dividends)	30% TDS	Capped $1M/yr (Form 15CA/CB)
RFC	Returning residents — hold foreign currency	Tax-free while RNOR	Freely repatriable
FCNR(B)	Fixed deposit in foreign currency (USD/GBP/EUR)	Tax-free (NRI/RNOR)	Unrestricted

RFC (Resident Foreign Currency) is the key account for returnees. You can hold USD/GBP/EUR earned abroad. Interest is tax-free during RNOR. Once you become ROR, interest becomes taxable. Convert RFC → regular savings when you settle permanently. No LRS limit on RFC deposits from your own foreign earnings.
Strategy: NRE for ongoing remittances · RFC for lump-sum foreign assets · NRO for India rental income · FCNR for USD FD without currency risk.

🇮🇪 Ireland-domiciled index funds (S&P500 / US exposure)

Why Ireland? Ireland has a tax treaty with the US reducing dividend withholding to 15% (vs 30% for most countries). Funds domiciled in Ireland are not considered US-sited assets — no US estate tax exposure for non-US investors holding Irish-domiciled ETFs.

Fund (UCITS)	Index	Domicile	Div. withheld
iShares Core S&P 500 (CSPX)	S&P 500	Ireland	15%
Vanguard S&P 500 UCITS (VUSA)	S&P 500	Ireland	15%
Invesco S&P 500 UCITS (SPXS)	S&P 500 (swap)	Ireland	0% (synthetic)
iShares MSCI World (IWDA)	MSCI World (60% US)	Ireland	15%

India tax treatment: Gains on these funds are treated as foreign equity/MF gains — taxable at India slab rate (not the 12.5% domestic equity rate). During RNOR, gains are exempt if proceeds not remitted to India. Once ROR, gains taxable at slab.
Key advantage: No US estate tax (not US-sited property). No US 1040-NR filing required post-departure. Traded on London Stock Exchange (LSE) and Euronext in USD/GBP/EUR.
Note: These are accumulating share class variants (CSPX, IWDA) — dividends reinvested, no annual income event. Distributing variants (VUSA) pay dividends. Verify current SEBI/RBI rules for resident Indians buying foreign ETFs — LRS $250k/yr cap applies.

🌍 Global S&P 500 funds — US estate tax bypass by domicile

US-domiciled ETFs (VOO, SPY, IVV) are US-sited assets — NRAs face 40% estate tax above a $60k exemption. These non-US domiciled alternatives track the same index but sit outside the US estate tax net. All are UCITS-compliant and tradeable from India via international brokers (Interactive Brokers, Saxo, etc.) under LRS.

Fund	Ticker	Index	Domicile	US div. WHT	Type	US estate tax?
iShares Core S&P 500	CSPX	S&P 500	🇮🇪 Ireland	15%	Accumulating	No ✓
Vanguard S&P 500 UCITS	VUSA	S&P 500	🇮🇪 Ireland	15%	Distributing	No ✓
Invesco S&P 500 UCITS	SPXS	S&P 500 (swap)	🇮🇪 Ireland	0% (synthetic)	Accumulating	No ✓
iShares MSCI World	IWDA	MSCI World (60% US)	🇮🇪 Ireland	15%	Accumulating	No ✓
Xtrackers S&P 500	XSPX	S&P 500	🇱🇺 Luxembourg	15%	Accumulating	No ✓
Amundi S&P 500 UCITS	500U	S&P 500	🇱🇺 Luxembourg	15%	Accumulating	No ✓
HSBC S&P 500 UCITS	HSPX	S&P 500	🇮🇪 Ireland	15%	Accumulating	No ✓
UBS S&P 500 UCITS	S5USAS	S&P 500	🇮🇪 Ireland	15%	Accumulating	No ✓
Vanguard VOO / iShares IVV / SPDR SPY	VOO/IVV/SPY	S&P 500	🇺🇸 USA	30%	Distributing	Yes ⚠ 40%

Why this matters: The last row (red) is the US-domiciled version most NRIs already hold — same index, same returns, but 40% estate tax exposure on balances above $60k. Every fund above it tracks the same S&P 500 with zero estate tax exposure.
Ireland vs Luxembourg: Both are treaty-favored (15% US dividend WHT vs 30% default). Ireland is the dominant UCITS domicile — deeper liquidity, tighter spreads. Luxembourg funds are equally estate-tax-exempt but slightly less liquid.
Accumulating vs Distributing: Accumulating reinvests dividends (no annual income event in India — simpler tax). Distributing pays dividends (creates a taxable event each year at ROR).
Synthetic (swap-based): SPXS uses swaps instead of holding US stocks directly — achieves 0% dividend leakage but carries counterparty risk.
How to buy: Open an international broker account (Interactive Brokers, Saxo) → use LRS ($250k/yr) to fund → buy on LSE/Euronext in USD or GBP. Cannot be purchased through Indian brokers (Zerodha, Groww) — those only offer domestic MFs.

⏳ SEPP / 72(t) early-withdrawal plans

What it is: Normally, taking money out of a 401(k)/IRA before age 59½ costs a flat 10% early-withdrawal penalty on top of ordinary income tax. SEPP (Substantially Equal Periodic Payments, IRC §72(t)) is the IRS's official escape hatch — elect it, commit to a fixed annual withdrawal schedule calculated by one of three approved methods, and the 10% penalty disappears on those withdrawals.

Question	Answer
How long am I locked in?	5 years or until you turn 59½ — whichever is longer. Start at 45 and you're locked in for ~14½ years, not 5.
Can I pause, change, or stop it?	No. No pausing, no changing the amount, no extra distributions, no additional contributions to the account during the lock-in window. (One narrow exception: you may switch to the RMD method once, IRS-wide, ever.)
What if I break it anyway?	The 10% penalty is reinstated retroactively on every distribution already taken — plus IRS underpayment interest computed from each original distribution date. A multi-year plan can generate a five-figure surprise bill.
Does moving to India pause it?	No. The IRS clock runs regardless of residency or citizenship. Breaking the schedule from overseas triggers the same retroactive penalty + interest — and is harder to unwind once you're filing as an NRA.
Which calculation method?	RMD (life-expectancy based, recalculated yearly — lowest payout, most forgiving) · Fixed Amortization (level payment, higher) · Fixed Annuitization (level payment, similar to amortization). All three are IRS-approved; pick based on how much income you actually need.
What if I die during SEPP?	Death terminates the plan immediately — no retroactive penalty. The IRS explicitly exempts death (§72(t)(2)(A)(ii)), so distributions already taken are not clawed back. The account passes to your named beneficiary as an Inherited IRA — they are not bound by your schedule and the 10% penalty never applies to inherited IRA distributions regardless of their age. Spouse beneficiary: can roll the account into their own IRA and treat it as their own — most flexibility, can defer RMDs to age 73. Non-spouse beneficiary (e.g. children): must fully distribute the account within 10 years (SECURE Act 2.0). No annual RMD required within those 10 years, but the account must be empty by year 10. India angle: if your beneficiary is an Indian ROR resident, distributions from the Inherited IRA are subject to US 30% NRA withholding, offset by DTAA Foreign Tax Credit against India slab — same treatment as your own withdrawals. Check that your beneficiary designation is current and aligns with your India estate plan (it overrides the will for retirement accounts).
India tax on SEPP withdrawals (ROR)	India taxes the net amount received (withdrawal − US withholding − any penalty) converted to INR at the prevailing rate, using Budget 2025 new-regime slabs (₹0 up to ₹4L, 5%→30% above, §87A rebate zeroes tax if total income ≤ ₹12L). If the US already withheld more than India's slab liability, the DTAA Foreign Tax Credit covers the difference and India collects nothing extra — shown as ~~₹XL~~ FTC in the withdrawal table. RNOR years: foreign income fully exempt, no India tax on any 401k distribution. NRI: not taxable in India.

Bottom line: SEPP can be the right tool if you genuinely need 401(k)/IRA income before 59½ and want to avoid the 10% penalty — but it trades a one-time 10% cost for a rigid, multi-year legal commitment that an international move makes meaningfully harder to manage. Toggle "Planned annual retirement withdrawal" in the Retirement tab to see a year-by-year SEPP-aware projection (with method estimates sized to your balance), and get a CPA/financial advisor to size the actual SEPP amount precisely before electing — this tool's figures are estimates only. 📋 IRS: SEPP FAQs ↗

⚠ Grey Areas — Not Fully Settled in Law

The following items involve genuine legal ambiguity — the tool shows conservative estimates, but outcomes may differ based on how your CPA/CA interprets the treaty, case law, or evolving CBDT guidance. Get professional advice before acting on any of these.

Topic	Grey Area	What This Tool Assumes	What Could Differ
India tax on Roth withdrawals	India has no concept of a "Roth IRA." Whether Roth withdrawals are tax-free in India (as they are in the US) is not settled.	Roth withdrawals shown as India tax-free (optimistic)	India may tax the full withdrawal as ordinary income at slab rates — especially the gains portion. No CBDT ruling or AAR decision directly addresses US Roth IRAs as of 2026.
Roth conversion — India tax	Converting Traditional 401k → Roth triggers US income tax. Whether India also taxes this "conversion income" at ROR is unclear.	RNOR: exempt (foreign income). ROR: taxable at slab with DTAA credit.	Some CAs argue the conversion isn't "income" under Indian law — it's an internal account transfer. Others treat it as taxable. No definitive guidance.
DTAA Article 20 — Pensions	Article 20 of the India-US treaty may exempt "pensions" from India tax. Whether a 401k qualifies as a "pension" under the treaty is disputed.	Conservative: 401k withdrawals taxable in India at slab (with DTAA FTC)	If your CA successfully argues Article 20 applies, India tax on 401k withdrawals could be $0. Some taxpayers have taken this position.
HSA — India treatment	India has no equivalent of an HSA. How to characterize HSA withdrawals under Indian tax law — medical expense reimbursement or foreign income — is not defined.	Conservative: taxable at ROR slab (medical withdrawals shown as India-exempt during RNOR)	Qualified medical withdrawals could arguably be exempt even at ROR since India doesn't tax medical reimbursements. No precedent.
ILIT 3-year look-back	Transferring a life insurance policy to an ILIT (irrevocable trust) removes it from your estate — but the IRS has a 3-year look-back rule (IRC §2035).	Tool shows trust-owned = $0 estate tax (assumes transfer was >3 years ago)	If you die within 3 years of transferring the policy to the ILIT, the death benefit is pulled back into your taxable estate as if the transfer never happened. Plan the transfer well before your move.
529 at Indian universities	529 "qualified" withdrawals require the institution to be on the US Dept. of Education's eligible list. No Indian university currently appears on this list.	Non-qualified withdrawal shown with 10% penalty + income tax	The list is updated periodically — an Indian university could be added in future. Check closer to withdrawal date.
Estate tax exemption sunset	The $13.61M US estate exemption is scheduled to roughly halve after 2025 unless Congress acts.	Tool uses the current $13.61M figure	If the exemption drops to ~$7M, more estates hit the threshold — especially combined with insurance and retirement assets. NRA $60k exemption is unaffected.

This is not an exhaustive list. Cross-border tax is inherently complex — every situation involves trade-offs, timing assumptions, and jurisdiction-specific interpretations that no single tool can fully capture. Use these estimates as a starting point for conversations with your CPA (US) and CA (India), not as a final answer.

US tax rate history — updated annually

Resident tax rates

Top marginal · 22% bracket thresholds · LTCG 20% threshold (MFJ)

IRS Rev. Proc. — brackets inflation-adjusted annually.

Non-resident alien (NRA) rates

Flat withholding · FIRPTA · Estate exemption · DTAA relief

FIRPTA increased 10%→15% in Feb 2016.

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Vibe coded with Claude · Built for NRIs returning home · Not tax advice — consult your CPA/CA

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