Do I have to file a tax return? In the United States it turns on gross income, filing status and age; for tax year 2025 a single filer under 65 files at $15,750. Canada uses a list of situations, not an income threshold. India requires a return when total income passes the basic exemption, and sometimes at any income.
Do I have to file a tax return? The three countries compared
| Question | United States | Canada | India |
|---|---|---|---|
| Main test | Gross income against a table by status and age | A list of situations | Total income against the basic exemption |
| Published in | IRS Publication 501 | CRA page; Income Tax Act section 150 | Department guidance on returns |
Who must file in the United States?
For tax year 2025 you must file if gross income is at least:
The U.S. trigger tracks the standard deduction. For 2025, the gross income that creates a duty to file is $15,750 for a single filer, $23,625 for head of household and $31,500 for a married couple filing jointly (or a qualifying surviving spouse). An extra $2,000 applies to an unmarried filer who is 65 or older, and $1,600 per spouse who is 65 or older on a joint return. A married person filing separately must file at just $5 of gross income. To count as 65 or older, you must have been born before January 2, 1961. Gross income means before deductions and includes worldwide income. A return is required at any income for net self-employment earnings of $400 or more, certain HSA or MSA distributions and church wages of $108.28 or more. File anyway to recover withholding or claim credits such as the earned income credit. Illinois adds a test: file if you must file federally or your Illinois base income exceeds $2,850 (2025).
Who must file in Canada?
The 2025 return was due April 30, 2026 (June 15 if you or your spouse is self-employed). You must file when any of these applies:
- You owe tax, or the CRA asks for a return.
- You sold capital property.
- You must repay Old Age Security or Employment Insurance benefits, or owe CPP on self-employment.
- You want to start or keep the Canada child benefit, the Canada Groceries and Essentials Benefit, the Guaranteed Income Supplement or the Canada workers benefit, or you elected pension splitting.
File even if not required, to carry forward tuition or losses and to build RRSP and FHSA room; the Canada Groceries and Essentials Benefit needs a 2025 return even with no income. See the T1 guide.
Who must file in India?
As of October 2026, for FY 2025-26 (assessment year 2026-27, Income-tax Act, 1961), file when total income before exemptions and Chapter VI-A deductions exceeds the basic exemption: under the old regime Rs 2.5 lakh (under 60), Rs 3 lakh (60 to 79) and Rs 5 lakh (80 and over); under the default regime Rs 4 lakh. A non-resident's old-regime figure is Rs 2.5 lakh at any age. The 2025 Act (section 263) keeps the rule.
File whatever your income if you:
- are a resident other than not ordinarily resident with foreign assets, signing authority abroad or a beneficial interest, or you claim a business or capital loss carry-forward;
- had current-account deposits over Rs 1 crore, foreign travel spending over Rs 2 lakh, electricity bills over Rs 1 lakh or savings deposits of Rs 50 lakh or more;
- have business turnover over Rs 60 lakh, professional receipts over Rs 10 lakh, or TDS or TCS of Rs 25,000 or more (Rs 50,000 for a resident 60 or over).
A return is also the only route to a refund. Exceptions: a resident aged 75 or over with only pension and same-bank interest can use a bank declaration, and a narrow NRI rule covers investment income and long-term gains fully taxed at source. See the NRI ITR guide.
Special cases for newcomers and NRIs
A new U.S. arrival's residency decides the form and the income that counts; see our first-year U.S. guide and the Canada newcomer guide. An NRI who becomes a resident other than not ordinarily resident meets the foreign-asset rule, even on small Indian income.
A worked example (invented numbers)
Hari and Lata, both 67 and green card holders in Aurora, file jointly. Their 2025 gross income is a $21,000 pension, $3,000 of interest and about $5,400 of Indian rent: $29,400, below the $34,700 joint threshold. They still file because $2,100 was withheld from the pension. Lata's Indian rent of Rs 4,50,000 exceeds the basic exemption, so she also files in India. Their daughter Asha, a Calgary student, owes no Canadian tax but files for the Canada Groceries and Essentials Benefit.
Mistakes and cross-border traps
- Testing net income instead of gross income in the U.S., or ignoring the $400 self-employment rule.
- Treating Canada's basic personal amount as the filing threshold.
- Mixing years; see tax years compared.
What we do
We prepare the U.S. side, including first-year returns for newcomers, and coordinate with your Canadian CPA and Indian Chartered Accountant, who decide the Canadian and Indian requirements. We do not prepare those returns. See individual tax return services and the tax questions hub.
Frequently asked questions
Must a retiree living on Social Security alone file a U.S. return?
Usually not. Benefits count only if you file separately from a spouse you lived with, or if half your benefits plus other income, including tax-exempt interest, exceeds $25,000 ($32,000 joint).
Do I have to file in Canada with no income?
Not necessarily, but you need a return to receive certain benefits and carry forward amounts.
Do I have to file in India below the basic exemption?
Generally no, unless a mandatory trigger applies, such as foreign assets.
Do NRIs have to file in India if TDS was deducted?
Only the narrow exception above. Most NRIs file to claim excess TDS.
Official sources
- IRS: Publication 501, Dependents, Standard Deduction, and Filing Information (2025)
- IRS: Instructions for Form 1040 (2025)
- Illinois Department of Revenue: Who must file
- CRA: Do you have to file a return?
- Income Tax Act (Canada), section 150
- Income Tax Department of India: Return of income guidance
- Income Tax Department of India: Threshold limits under the Income-tax Act
- Income Tax Department of India: Return applicable for senior citizens, AY 2026-27
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.