Residency and Filing Terms: US, Canada, India Glossary

Residency and filing terms decide which country taxes what, which form you file and when. A person who is a "resident" under U.S. rules can be a "non-resident" under Indian rules in the same year, and each country issues its own taxpayer number. This glossary defines the key residency and filing terms in plain English, matches them across the three countries and links to the full guides.

Residency and filing terms at a glance

Concept	United States	Canada	India
Tax resident	Resident alien: green card or substantial presence test	Resident: residential ties or 183 days	Resident: day-count tests
Not a resident	Nonresident alien	Non-resident	Non-resident (an NRI if an Indian citizen or person of Indian origin abroad)
Part-year or in-between	Dual-status alien	Part-year resident (immigrant or emigrant)	Resident but not ordinarily resident (RNOR)
Treaty tool	Form 8833, Form 6166	Treaty tie-breaker	Tax residency certificate and Form 10F
Personal tax ID	SSN or ITIN	SIN	PAN
Annual return	Form 1040 or 1040-NR	T1	ITR-1 to ITR-7
Extension	Form 4868	None on request	None; a belated return follows
Correct a filed return	Form 1040-X	T1-ADJ	Revised or updated return

Terms A to E

Aadhaar

Aadhaar is India's 12-digit resident identity number. Residents generally link it to their PAN; NRIs without Aadhaar are usually not required to, but confirm with your Chartered Accountant (CA). See PAN, TAN and Aadhaar.

Equivalents: U.S., SSN. Canada, SIN.

Amended return

An amended return corrects a filed return. The U.S. uses Form 1040-X, Canada uses Form T1-ADJ or the online change request, and India uses a revised return, or an updated return once the revision window has closed. See amended returns and corrections by country.

Assessment year and tax year (India)

Under the Income-tax Act, 1961, income of a financial year (previous year) is assessed in the following assessment year, so income of April 2025 to March 2026 is reported for assessment year 2026-27. The Income-tax Act, 2025 replaces both labels with "tax year" from April 1, 2026. See what the India income tax act 2025 changes.

Belated return

A belated return is filed in India after the original due date but within the extended time limit, usually with a late fee and interest. For assessment year 2026-27 the non-audit due dates have passed, so this is the route for late filers; the time limit is confirmed by your CA. See NRI ITR filing step by step.

Equivalents: U.S. and Canada, a late return with penalties.

Closer connection exception

A person who meets the substantial presence test can still be treated as a U.S. nonresident by filing Form 8840 and showing a tax home and closer connection to a foreign country. You must have been in the U.S. fewer than 183 days in the year and cannot have a green card application pending. See snowbirds and Form 8840.

Equivalents: Canada, residential ties analysis. India, no direct match.

Deemed resident (Canada)

Canada treats you as a resident for the year if you sojourn there for 183 days or more, even without other ties. Newcomers with a home, spouse or dependants in Canada are usually factual residents from the day they arrive. See Canadian tax residency rules.

Departure tax

When you emigrate from Canada, most property is treated as sold at fair market value on departure, with exceptions for items such as Canadian real estate. U.S. citizens and long-term residents face a separate expatriation regime. See moving from Canada to India.

Due date

U.S. individual returns are due April 15 (April 15, 2026 for tax year 2025). Canadian returns are due April 30, or June 15 for self-employed people, although any tax owing is still due April 30. India's usual date for non-audit individuals is July 31, while audit cases for assessment year 2026-27 are due November 21, 2026 under CBDT Circular 07/2026. See tax year and deadlines compared.

Dual-status alien

A dual-status year is the year you change between nonresident and resident alien in the U.S., commonly the year of arrival or departure. You file a return that treats each part of the year differently and attach the statement the IRS requires. See U.S. tax residency tests explained.

Equivalents: Canada, part-year resident. India, RNOR is a different concept.

Election to be taxed as a resident alien

A nonresident alien who is married to a U.S. citizen or resident alien at year-end may elect to be taxed as a U.S. resident for the whole year by filing a joint Form 1040 with a required statement. Both spouses' worldwide income then becomes taxable in the U.S., the choice can cost some treaty benefits, and it can be made only once.

E-verification

After you file an Indian return you must e-verify it, for example by Aadhaar OTP or net banking, within the time shown on the e-Filing portal; an unverified return is treated as not filed. See the portal and AIS guide.

Extension (Form 4868)

Form 4868 gives most U.S. individuals up to six months to file, to October 15, 2026 for 2025 returns. It does not extend the time to pay, and filers living abroad on the due date may get an automatic two months. See tax extensions by country.

Terms F to P

Filing status

U.S. filers choose single, married filing jointly, married filing separately, head of household or qualifying surviving spouse, which sets the standard deduction and brackets. Canada and India tax individuals separately regardless of marital status. See the Form 1040 roadmap.

Financial year (India)

India's financial year runs from April 1 to March 31, and individuals' tax follows it. This differs from the calendar year used in the U.S. and Canada. See the India tax system and financial year.

Form 8843 and exempt individuals

Students, teachers, trainees and certain other visitors on specified visa types do not count some days toward the substantial presence test. Claiming that exclusion requires Form 8843, and filing it late can forfeit the benefit. See U.S. tax for students and scholars.

Green card test

You are a U.S. resident alien if you are a lawful permanent resident at any time during the year. The status generally ends only when it is revoked or abandoned in the formal way. See U.S. tax return for first-year newcomers.

Individual Taxpayer Identification Number (ITIN)

An ITIN is a nine-digit number the IRS issues, using Form W-7, to people who must file but cannot get an SSN. It starts with 9, and it does not qualify you for credits and deductions that require an SSN. See SSN and ITIN.

ITR forms

India has seven forms. ITR-1 suits resident individuals with simple income, so NRIs generally use ITR-2 (no business income) or ITR-3 (business or professional income), while ITR-4 serves small presumptive-taxation filers. See NRI ITR filing step by step.

Non-resident Indian (NRI)

An NRI is an Indian citizen or person of Indian origin who lives outside India. FEMA and income tax law use different tests, so you can be an NRI for banking and a resident for tax in the same year. See NRI income taxable in India.

Nonresident alien (NRA)

A nonresident alien is a non-citizen who passes neither the green card nor the substantial presence test. NRAs file Form 1040-NR on U.S.-source income, with wage earners due April 15 and others June 15 for 2025. See nonresident FDAP and ECI.

Part XIII tax

Canada withholds 25 percent on certain passive income paid to non-residents unless a treaty or domestic rule lowers it, and non-residents may use sections 216 and 217 to file a return on some income. See Canada for non-residents.

Permanent Account Number (PAN)

PAN is India's 10-character taxpayer number, required for returns, bank deposits and many investments. A business that deducts tax also holds a TAN. See PAN, TAN and Aadhaar.

Equivalents: U.S., SSN or ITIN. Canada, SIN.

Terms R to Z

Resident alien

A resident alien is taxed on worldwide income like a citizen, and passes either the green card test or the substantial presence test. First-year choice and dual-status rules may apply in the arrival year. See U.S. tax residency tests explained.

Resident but not ordinarily resident (RNOR)

India uses RNOR for people who are tax residents but have recently arrived or lived abroad for long periods. An RNOR is generally taxed on India-source income and not on foreign income unless it arises from a business controlled in India. Returning NRIs often qualify for a short window, so ask your CA. See resident, NRI and RNOR.

Residential ties

The CRA looks first at primary ties: a home in Canada, a spouse or common-law partner who lives in Canada and dependants in Canada. Secondary ties such as a driver's licence, bank accounts and provincial health coverage add weight. See Canadian tax residency rules.

A SIN is Canada's nine-digit identifier, issued in person by Service Canada. Newcomers need one to work, file and apply for benefits. See Canada tax for newcomers.

Equivalents: U.S., SSN. India, PAN for tax.

An SSN is issued by the Social Security Administration to citizens and to non-citizens authorized to work. Credits like the child tax credit and the new tips and overtime deductions require one. See SSN and ITIN.

Statement of income (Canadian newcomers)

New residents report income earned outside Canada for up to two years before arrival, converted at the Bank of Canada rate, to help the CRA calculate benefits. See Canada tax for newcomers.

Substantial presence test

You are a U.S. resident for the year if you were present at least 31 days in the year and 183 weighted days over three years: all current-year days, one-third of last year's days and one-sixth of the year before's. Some days do not count, such as certain student and exempt-individual days. See residency tests compared.

Tax home

Your tax home is your regular or main place of business or work, regardless of where your family lives. It matters for the foreign earned income exclusion and for the higher Form 8938 thresholds that apply to people living abroad.

Tax residency certificate (TRC) and Form 10F

To claim India-treaty benefits, a non-resident gives the payer a TRC from the home country's tax authority and Form 10F. The IRS issues Form 6166 as proof of U.S. residency. See treaties and Form 10F.

Treaty tie-breaker

When two countries both treat you as resident, a tax treaty usually decides by looking, in order, at your permanent home, your centre of vital interests, your habitual abode and your citizenship. See the three-country residency tie-breaker.

Updated return (ITR-U)

An updated return lets you correct or add income to an Indian return after the normal revision period, usually on payment of additional tax. Ask your CA whether the window is open for the year in question. See NRI ITR filing step by step.

How we can help

We determine your U.S. residency status and prepare the U.S. return from the Aurora, Illinois area, and we coordinate with your Canadian CPA or Indian Chartered Accountant on their sides. See relocation and immigration tax planning and individual returns for newcomers and NRIs. Browse the full tax and compliance glossary for the other term sets.

Frequently asked questions

Can I be a resident of two countries in the same year?

Yes. Each country applies its own tests. A treaty tie-breaker then decides which country treats you as resident for treaty purposes.

Is an NRI the same as a nonresident alien?

No. NRI is an Indian-law and FEMA concept. A nonresident alien is a U.S. tax status. An Indian citizen with a U.S. green card is usually an NRI in India and a U.S. resident alien.

What number do I need before I can file in each country?

A U.S. filer needs an SSN or ITIN, a Canadian filer needs a SIN, and an Indian filer needs a PAN.

Which glossary covers penalties and notices?

See the penalty, notice and compliance glossary.

Official sources

This page summarizes public guidance in plain language. If anything here differs from the official source, the official source controls.

General information only. It is not tax, legal, accounting or immigration advice for your situation, and rules change; confirm the current rules with the official source or a licensed professional in the relevant country.