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US Tax Return Filing, FBAR, FATCA, PFIC, Foreign Asset Reporting & US-India Tax Advisory
Living outside the United States does not necessarily end your US tax obligations. If you are a US Citizen, Green Card Holder, H-1B or L-1 visa holder, US resident under the Substantial Presence Test, or a US citizen living in India, you may still be required to file annual US tax returns and disclose foreign financial assets even if you no longer live in America.
For Indians with financial interests in both India and the United States, US tax compliance can become particularly complex. Income earned in India, NRE and NRO bank accounts, Indian mutual funds, RSUs, ESOPs, rental properties, capital gains, retirement accounts, foreign trusts, partnership interests, and overseas companies may all have reporting implications under US tax laws.
In addition to filing Form 1040 or Form 1040NR, many taxpayers must also comply with FBAR (FinCEN Form 114), FATCA (Form 8938), PFIC reporting (Form 8621), Foreign Trust reporting (Forms 3520 & 3520-A), Foreign Corporation reporting (Form 5471), Foreign Partnership reporting (Form 8865), and various other IRS disclosure requirements.
Failure to comply can result in substantial penalties, even where no additional tax is payable.
At Dinesh Aarjav & Associates, our team of Chartered Accountants, US CPAs, Enrolled Agents (EAs), and international tax professionals assists NRIs, Green Card Holders, US Citizens, expatriates, startup founders, executives, investors, and global families with comprehensive US tax compliance. Our services cover annual tax return preparation, foreign asset reporting, cross-border tax planning, US-India DTAA advisory, foreign tax credit planning, Streamlined Filing Compliance Procedures, IRS notice support, and tax-efficient planning for individuals with financial interests in both countries.
Whether you have recently moved to India, continue to work in the United States, hold Indian investments, or are planning to return to India, our integrated India-US tax advisory helps you remain compliant while minimizing double taxation
Unlike many countries, the United States generally taxes its citizens and certain other taxpayers on their worldwide income, regardless of where they reside.
This means a US citizen living permanently in India may still need to file annual US tax returns and disclose foreign assets, even if all income is earned outside the United States.
US tax compliance therefore extends far beyond filing Form 1040. Taxpayers may also need to report:
At the same time, tax treaties and foreign tax credit provisions often help reduce or eliminate double taxation where income is taxed in both India and the United States.
Understanding these interactions requires coordinated advice from professionals familiar with both tax systems.
Many individuals incorrectly assume that moving outside the United States ends their US filing obligations. In reality, filing requirements depend on citizenship, immigration status, residency tests, income thresholds, and ownership of foreign assets.
We regularly assist the following categories of taxpayers.
US citizens generally remain subject to US tax filing obligations regardless of where they live.
This includes:
Typical compliance includes:
Lawful Permanent Residents generally continue to have US filing obligations until their Green Card status is formally terminated or abandoned under applicable rules.
We assist Green Card Holders with:
Many H-1B and L-1 professionals become US tax residents after satisfying the Substantial Presence Test.
Depending on residency status, they may require:
We also advise professionals relocating between India and the US on tax residency planning.
International students often have unique filing requirements.
Our services include:
US citizens residing in India frequently face taxation in both countries.
We assist with:
Returning NRIs often continue to have US filing obligations after relocating.
We help clients coordinate:
Whether you are a US Citizen living in India, Green Card Holder, H-1B professional, NRI returning to India, or an individual with complex cross-border investments, timely planning can help you remain compliant while reducing the risk of penalties and unnecessary double taxation.
At Dinesh Aarjav & Associates, our team of Chartered Accountants, US CPAs, Enrolled Agents, and international tax specialists provides end-to-end assistance with US tax returns, Form 1040, FBAR (FinCEN Form 114), FATCA (Form 8938), PFIC reporting (Form 8621), Foreign Tax Credits (Form 1116), Foreign Earned Income Exclusion (Form 2555), US–India DTAA advisory, Streamlined Filing Compliance Procedures, IRS notices, and ongoing cross-border tax planning.
Whether your tax situation is straightforward or involves complex international reporting, we help you navigate US tax compliance with confidence while coordinating both your Indian and US tax obligations
Our US tax practice supports a broad range of individuals with cross-border tax obligations.
We regularly advise:
Whether you have simple salary income or a complex international investment portfolio, we tailor our advisory to your personal and financial circumstances.
Understanding US filing deadlines is essential to avoid late-filing penalties and interest.
| Filing Requirement | Typical Due Date* |
|---|---|
| Form 1040 | April 15 |
| Automatic Extension for Taxpayers Living Abroad | June 15 |
| Extended Return Due Date (with extension) | October 15 |
| FBAR (FinCEN Form 114) | April 15 (automatic extension generally available to October 15) |
| Estimated Tax Payments | Quarterly, where applicable |
| FATCA (Form 8938) | Filed with Form 1040 |
* Deadlines may vary in certain years due to weekends, holidays, or IRS announcements. Taxpayers should verify the applicable due dates for the relevant filing year.
Timely filing is particularly important for taxpayers claiming foreign tax credits, treaty benefits, or the Foreign Earned Income Exclusion, as late filing may affect the availability of certain elections and relief provisions.
US international tax compliance extends well beyond filing Form 1040. Depending on your income, residency status, investments, and ownership interests, multiple IRS forms may be required.
Our team prepares and advises on a comprehensive range of US federal tax returns and international information returns, ensuring accurate reporting and coordinated India-US tax planning.
We assist with:
Form 1040 is the primary individual income tax return required for US Citizens and US Resident Alians. It reports worldwide income, including salary, self-employment income, rental income, interest, dividends, capital gains, retirement income, and foreign income. Taxpayers may also claim deductions, tax credits, Foreign Tax Credits (Form 1116), or the Foreign Earned Income Exclusion (Form 2555), where applicable.
Form 1040NR is generally filed by individuals who are classified as Nonresident Aliens for US tax purposes but have US-source income. This may include employment income, business income, investment income, scholarships, or certain capital gains. Residency under the Substantial Presence Test and applicable treaty provisions determine whether Form 1040 or Form 1040NR is required.
The Foreign Bank Account Report (FBAR), filed electronically as FinCEN Form 114, is required where the aggregate value of foreign financial accounts exceeds the prescribed threshold during the calendar year. For taxpayers with financial interests in India, reportable accounts may include NRE Accounts, NRO Accounts, resident savings accounts, fixed deposits, foreign currency accounts, brokerage accounts, demat accounts, and certain other financial accounts. Failure to file an FBAR can result in significant civil penalties, making timely and accurate reporting essential.
Form 8938, required under the Foreign Account Tax Compliance Act (FATCA), is filed with the US income tax return to disclose specified foreign financial assets where applicable reporting thresholds are met. Reportable assets may include foreign bank accounts, investment accounts, shares of foreign companies, partnership interests, foreign pensions, certain insurance products, and other overseas financial assets. FATCA reporting is separate from FBAR, and in many cases taxpayers may have obligations under both regimes.
Form 1116 enables eligible taxpayers to claim a Foreign Tax Credit (FTC) for income taxes legally paid to a foreign country, thereby helping reduce double taxation. This form is particularly relevant for US Citizens, Green Card Holders, and US Residents earning income in India, including salary, rental income, dividends, capital gains, and business income. Proper Foreign Tax Credit planning under the US–India Income Tax Treaty (DTAA) can significantly reduce the overall global tax burden.
Eligible taxpayers working outside the United States may claim the Foreign Earned Income Exclusion (FEIE) using Form 2555. Subject to the applicable statutory conditions, qualifying foreign earned income may be excluded from US taxation by satisfying either the Physical Presence Test or the Bona Fide Residence Test. Choosing between the Foreign Earned Income Exclusion and the Foreign Tax Credit often requires detailed analysis to determine the most tax-efficient approach.
Form 8621 is used to report investments in Passive Foreign Investment Companies (PFICs). For many US taxpayers residing in India, Indian Mutual Funds, SIPs, ELSS Funds, certain ETFs, ULIPs, and similar pooled investment vehicles may be classified as PFICs under US tax law. PFIC reporting is one of the most technically challenging areas of US international taxation and may involve complex tax computations, excess distribution rules, Qualified Electing Fund (QEF) elections, or Mark-to-Market (MTM) elections.
Forms 3520 and 3520-A relate to reporting obligations involving foreign trusts, ownership of foreign trusts, distributions from foreign trusts, and receipt of certain large foreign gifts or inheritances. These reporting requirements commonly arise where US taxpayers have family wealth structures, overseas estate planning arrangements, or receive substantial gifts from relatives residing outside the United States. Failure to comply can result in substantial penalties even where no tax is payable.
Form 5471 is required for certain US persons who are officers, directors, or shareholders of specified foreign corporations. This reporting commonly applies where US taxpayers own or control Indian Private Limited Companies, overseas holding companies, startup entities, or foreign operating businesses. The reporting requirements are extensive and may include financial statements, ownership disclosures, income information, balance sheets, and related-party transactions.
Form 8858 is used to report information relating to certain Foreign Disregarded Entities (FDEs) and foreign branches owned by US taxpayers. The form captures details regarding ownership, financial activity, income, deductions, and operations of foreign entities that are treated as disregarded for US federal income tax purposes. Accurate reporting is particularly important for entrepreneurs, consultants, and global business owners operating through overseas entities.
Form 8865 applies to certain US taxpayers with ownership interests in foreign partnerships, including Indian LLPs and overseas partnership structures. Depending on the level of ownership and control, the form may require extensive reporting of partnership income, capital accounts, balance sheets, ownership interests, and transactions between partners. These reporting requirements are highly technical and should be evaluated carefully for cross-border business structures.
Form 8833 is used to disclose certain treaty-based return positions taken under an applicable tax treaty, including the US–India Double Taxation Avoidance Agreement (DTAA). It may be required where a taxpayer claims treaty benefits that modify the application of US domestic tax law. Proper evaluation of treaty provisions, including relief from double taxation, taxation of students and researchers, pensions, and other treaty articles, is essential before claiming treaty positions.
One of the biggest concerns for US Citizens, Green Card Holders, and NRIs with financial interests in both India and the United States is the possibility of double taxation.
The United States generally taxes its citizens and resident taxpayers on their worldwide income, irrespective of where they live. At the same time, India taxes individuals based on their residential status and the source of income. Without proper planning, the same income may become taxable in both countries.
The United States-India Double Taxation Avoidance Agreement (DTAA) helps allocate taxing rights between the two countries and provides relief through treaty provisions and Foreign Tax Credits.
The treaty can be particularly relevant for taxpayers receiving:
Our India-US tax specialists help clients interpret treaty provisions, analyse cross-border income, and determine the most tax-efficient reporting approach.
Proper treaty planning can significantly reduce the overall global tax burden while ensuring compliance with both IRS and Indian Income Tax regulations.
Many US taxpayers residing in India pay income tax to the Indian Government on salary, rental income, business income, capital gains, dividends, and investment income.
Without proper planning, the same income may also become taxable in the United States.
Form 1116 allows eligible taxpayers to claim a Foreign Tax Credit (FTC) for income taxes legally paid to India, thereby reducing or eliminating double taxation.
Our advisory includes:
We also assist with supporting documentation, limitation calculations, allocation of foreign taxes, and preparation of Form 1116.
Many taxpayers incorrectly believe that only foreign bank accounts generating taxable income need to be reported to the US Government.
In reality, FBAR (FinCEN Form 114) is an information reporting requirement and is separate from your US income tax return.
If the aggregate value of all your foreign financial accounts exceeds USD 10,000 at any time during the calendar year, you may be required to electronically file an FBAR (FinCEN Form 114) with the US Financial Crimes Enforcement Network (FinCEN).
This threshold applies to the combined value of all foreign accounts—not each account individually.
Failure to file an FBAR may result in significant civil penalties. For non-willful violations, penalties may be up to USD 10,000 per violation, while substantially higher penalties may apply in cases involving willful non-compliance.
FBAR and FATCA are often confused, but they are two separate reporting regimes.
While FBAR is filed electronically with FinCEN, Form 8938 is filed with the IRS as part of your Form 1040.
For many taxpayers residing in the United States, Form 8938 generally applies where specified foreign financial assets exceed:
| Filing Status | Year-End Threshold |
|---|---|
| Single | USD 50,000 |
| Married Filing Jointly | USD 100,000 |
Taxpayers living outside the United States are generally subject to higher reporting thresholds, depending on their filing status. Professional advice should be obtained to determine whether Form 8938 is required.
Many taxpayers are required to file both FBAR and Form 8938, as the reporting requirements are different.
Many investment products that are perfectly acceptable under Indian tax laws may trigger complex US reporting obligations.
US taxpayers holding these investments may be required to file Form 8621 annually.
PFIC taxation is often significantly less favourable than ordinary capital gains taxation.
Professional advice should always be obtained before investing in Indian mutual funds or other pooled investment products if you are subject to US tax laws.
Many taxpayers believe that only US assets need to be disclosed on their US tax returns.
However, depending on the applicable reporting rules, many Indian financial assets may also need to be reported.
| Indian Asset | FBAR | FATCA | Other IRS Forms |
|---|---|---|---|
| NRE Account | ✓ | May Apply | — |
| NRO Account | ✓ | May Apply | — |
| Resident Savings Account | ✓ | May Apply | — |
| Fixed Deposits | ✓ | May Apply | — |
| FCNR Deposits | ✓ | May Apply | — |
| Demat Account | ✓ | May Apply | — |
| Brokerage Account | ✓ | May Apply | — |
| Indian Mutual Funds | — | May Apply | Form 8621 |
| Shares of Indian Companies | — | May Apply | Form 5471 (where applicable) |
| LLP Interest | — | May Apply | Form 8865 |
| Partnership Interests | — | May Apply | Form 8865 |
| Foreign Trust | — | May Apply | Forms 3520 & 3520-A |
| Foreign Pension | May Apply | May Apply | Depends on facts |
| Cash Value Insurance | May Apply | May Apply | Depends on facts |
Reporting requirements depend on the taxpayer's ownership, filing status, value of assets, and the applicable IRS rules.
Interest earned on Indian fixed deposits generally forms part of worldwide income for US tax purposes.
Dividends received from Indian companies are generally reportable on the US tax return.
Business or professional income earned in India should be analysed under both Indian tax law and US tax law, together with the US–India DTAA.
The taxation of pension income depends on the source of the pension, treaty provisions, and the taxpayer's circumstances.
Indian cryptocurrency transactions and digital asset investments may also have US reporting and tax implications.
Many US taxpayers unknowingly make reporting mistakes that may lead to penalties or increased IRS scrutiny.
Some of the most common mistakes include:
Early planning, annual compliance reviews, and coordinated India-US tax advice can significantly reduce compliance risks and improve overall tax efficiency.
Many US Citizens, Green Card Holders, and US taxpayers living in India discover years later that they were required to file US tax returns, FBARs, or international information returns—even though they were paying taxes in India and believed they had no US filing obligations.
To help eligible taxpayers become compliant, the IRS offers the Streamlined Filing Compliance Procedures for individuals whose previous non-compliance was non-willful.
Non-willful generally means the failure to file or report foreign financial assets resulted from negligence, inadvertence, mistake, or a genuine misunderstanding of the US tax rules.
Depending on the taxpayer's circumstances, the Streamlined Procedures may involve:
Every case should be reviewed individually before making any voluntary disclosure to the IRS.
Receiving an IRS notice can be stressful, particularly for taxpayers residing outside the United States.
An IRS notice does not necessarily mean additional tax is payable. In many cases, the IRS simply seeks clarification, supporting documentation, or additional information regarding income, deductions, foreign tax credits, or international reporting.
We prepare technically robust responses supported by appropriate documentation and help clients navigate IRS correspondence efficiently.
Early identification of filing obligations and timely corrective action can significantly reduce compliance risks.
| Non-Compliance | Potential Consequences* |
|---|---|
| Late Filing of Form 1040 | Failure-to-file penalty generally calculated at 5% of unpaid tax per month, up to a maximum of 25% |
| Failure to File FBAR (FinCEN Form 114) | Up to USD 10,000 per non-willful violation, with significantly higher penalties possible for willful violations |
| Failure to File Form 8938 (FATCA) | Initial penalties generally begin at USD 10,000, with additional penalties potentially applying where non-compliance continues after IRS notification |
| Failure to File Form 8621 (PFIC Reporting) | May result in interest charges on certain unpaid tax, unfavourable tax treatment, and increased IRS scrutiny depending on the facts |
| Failure to File Forms 3520 / 3520-A | Significant penalties may apply depending on the value of reportable transactions and the nature of non-compliance |
| Failure to File Form 5471 | Significant information return penalties may apply for failure to report foreign corporation interests |
| Failure to File Form 8865 | Penalties may apply for failure to report interests in foreign partnerships |
* Penalties are prescribed under US tax law and depend on the taxpayer's individual facts, the nature of the non-compliance, and the availability of statutory relief.
If you have missed filing US tax returns, FBARs, FATCA disclosures, or international information returns, it is generally advisable to seek professional advice before making corrective filings.
At Dinesh Aarjav & Associates, we believe US tax compliance should extend beyond annual return preparation. Our process is designed to help clients remain compliant while proactively managing cross-border tax risks.
We begin by understanding your:
Our specialists review all relevant documents, including:
Our team analyses:
We prepare all applicable US tax returns and international information returns, including:
Every return undergoes multiple levels of review before filing.
We assist with:
Unlike firms that only prepare annual tax returns, we continue to advise clients throughout the year on matters such as:
Choosing the right advisor for US tax compliance is about much more than preparing Form 1040.
Cross-border taxation requires expertise in US tax laws, Indian tax laws, the US–India DTAA, international information reporting, foreign tax credits, and practical planning for globally mobile individuals and families.
Our multidisciplinary team combines Indian and US tax expertise to provide integrated cross-border advisory.
Our objective is not merely to prepare tax returns but to help clients remain compliant while reducing tax risks and avoiding unnecessary double taxation.
Advised a US citizen residing in India on salary reporting, Indian rental income, FBAR filing, FATCA compliance, PFIC reporting for Indian mutual funds, and Foreign Tax Credit planning under the US–India DTAA.
Supported a software professional relocating permanently to India with departure-year US tax filing, FBAR compliance, Foreign Tax Credit planning, 401(k) advisory, and coordination of US and Indian tax obligations.
Assisted a US-based entrepreneur with Form 5471 reporting, ownership disclosures, cross-border restructuring, international information returns, and annual US tax compliance.
If you’re an NRI with income sourced from the US, such as salary, dividends, rental income, or capital gains, you are required to file a US tax return. Additionally, even if your income is entirely foreign, you must file if your global income exceeds the filing thresholds set by the IRS. These thresholds depend on your filing status (Single, Married Filing Jointly, etc.) and age.
The standard deadline for filing US tax returns is April 15th each year. If April 15th falls on a weekend or holiday, the deadline extends to the next business day. For those unable to meet the deadline, a six-month extension is available, pushing the due date to October 15th. However, the extension applies only to filing, not payment. Interest and penalties may apply if taxes owed are not paid by April 15th.
Missing the deadline can result in penalties: Late Filing Penalty: 5% of unpaid taxes for each month the return is late, up to 25%. Late Payment Penalty: 0.5% of the unpaid taxes for each month the taxes remain unpaid. Additionally, interest accrues daily on unpaid taxes and penalties. Filing as soon as possible minimizes these charges.
Yes, NRIs can claim relief for foreign taxes paid under the Foreign Tax Credit (FTC). The FTC allows you to offset US tax liability by the amount of taxes paid to another country, provided the income is subject to taxation in both countries. To claim this credit, you must file Form 1116 with your US tax return.
The IRS requires NRIs to report worldwide income on Form 1040, regardless of where the income is earned. This includes income from employment, investments, rental properties, and business activities abroad. Specific reporting rules may apply depending on the type of foreign income and whether it qualifies for exclusions or credits under US tax laws.
The Global Intangible Low-Taxed Income (GILTI) tax applies to income earned through Controlled Foreign Corporations (CFCs). If you hold significant ownership in a foreign corporation, you may be required to report GILTI using Form 8992. This tax aims to reduce tax deferral on foreign earnings.
Payments can be made online through the IRS website or by international wire transfer.
To file accurately, gather the following documents: W-2 Forms: For income from US employers. 1099 Forms: For income from interest, dividends, freelance work, or capital gains. Foreign Income Records: Bank statements or pay stubs for income earned abroad. Form 8938 (FATCA) or FBAR: For foreign financial accounts exceeding reporting thresholds. Proof of Deductions/Credits: Receipts for deductible expenses like mortgage interest or education.
Yes, you can amend your return using Form 1040-X within three years of the original filing date or two years from the date the tax was paid, whichever is later. Amending is useful for correcting errors, claiming missed deductions, or adjusting income.
Yes. If you are a US citizen, Green Card holder, or meet the Substantial Presence Test, you are required to file US tax returns even if you reside outside the US. This includes reporting worldwide income
• FBAR (FinCEN Form 114) – if you have foreign bank accounts exceeding $10,000 • Form 8938 (FATCA) – for specified foreign financial assets • Form 8621 – for investments in Passive Foreign Investment Companies (PFICs) • Form 5471 – for ownership in foreign corporations • Form 3520/3520-A – for foreign trusts and gifts
FATCA (Foreign Account Tax Compliance Act) requires NRIs and expats to report specified foreign financial assets if their total value exceeds certain thresholds. Non-compliance can lead to hefty IRS penalties.
Failure to report income or file mandatory forms like FBAR, Form 8938, or Form 5471 can lead to civil and criminal penalties. FBAR violations alone can carry penalties of up to $10,000 per account, per year (non-willful).
Yes. NRIs can claim Foreign Tax Credit (Form 1116) or opt for Foreign Earned Income Exclusion (Form 2555) depending on eligibility. These provisions help avoid double taxation.
Yes. Indian Provident Fund (PF), NRE, NRO, mutual funds, and even certain LIC policies may be reportable under FBAR and Form 8938. They may also be treated as PFICs, requiring Form 8621
A Passive Foreign Investment Company (PFIC) includes most foreign mutual funds. US taxpayers must file Form 8621 for each PFIC and are subject to complex taxation rules and interest charges on gains.
The IRS provides options like the Streamlined Foreign Offshore Procedures for late filers to come into compliance without facing full penalties. We can help assess your eligibility.
US Citizens, Green Card Holders, and certain US tax residents may continue to have annual US filing obligations even while residing in India. Filing requirements depend on citizenship, residency status, income, and ownership of foreign financial assets.
Yes. US citizens are generally required to report their worldwide income regardless of where they live. Foreign Tax Credits, treaty provisions, and other relief mechanisms may help reduce double taxation.
If you have missed one or more years of US tax returns, you should seek professional advice before making corrective filings. Depending on your circumstances, you may be eligible for IRS relief programmes such as the Streamlined Filing Compliance Procedures.
Failure to file an FBAR does not automatically mean severe penalties will apply. The consequences depend on the facts and circumstances, including whether the failure was non-willful or willful. In appropriate cases, taxpayers may be able to regularise past non-compliance through available IRS procedures.
Although both FBAR and FATCA require reporting of foreign financial assets, they are separate compliance regimes. FBAR (FinCEN Form 114) is filed electronically with FinCEN, while Form 8938 is filed with the IRS as part of the annual US income tax return. Many taxpayers may have reporting obligations under both regimes.
Depending on the applicable thresholds and reporting requirements, NRE and NRO accounts may need to be disclosed under FBAR and/or FATCA. The reporting obligation depends on the aggregate value of foreign financial accounts and specified foreign financial assets.
Although NRE account interest may be exempt from tax in India under specified conditions, it may still need to be reported under US tax rules. The applicable tax treatment depends on the taxpayer's circumstances.
Indian mutual funds may be classified as Passive Foreign Investment Companies (PFICs) under US tax law, which can trigger Form 8621 reporting and specialised tax calculations.
Yes. We assist clients in reviewing IRS notices, preparing responses, compiling supporting documentation, and managing cross-border tax issues arising from IRS correspondence.
Not necessarily. Green Card Holders generally continue to have US tax filing obligations until their lawful permanent resident status has been formally relinquished or otherwise ceases under applicable US tax law.
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With over 21 years of experience, Mr. Abhishek Batra specializes in NRI taxation and cross-border corporate tax strategies. His expertise spans tax planning, compliance advisory, and financial structuring, helping individuals and businesses navigate complex international tax regulations.
Based in Canada, Mr. Batra offers tailored solutions to NRIs, expatriates, and global companies with operations in India. A Chartered Accountant, CPA, and SRCC graduate, he is known for delivering impactful financial strategies that support growth and compliance.
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An Experienced Chartered Accountant with over 5 years of expertise in cross-border taxation, NRI taxation, and US tax compliances. She has extensive exposure in handling complex international tax matters, including India-US taxation, DTAA advisory, foreign disclosures, expatriate taxation, and tax planning for NRIs and returning Indians.
She is a Chartered Accountant and a Commerce Graduate, with strong proficiency in US tax filings and global tax advisory services.
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