Relocation and immigration tax planning is the work you do before you move, not after: choosing arrival and departure dates, deciding which assets to sell where, and lining up accounts so that three countries do not each tax the same gain. Our firm plans the U.S. side of moves into and out of the United States and coordinates with your Canadian CPA and Indian CA on the Canadian and Indian side. This is tax planning, not legal or immigration advice, and visa, green card and citizenship questions belong with an immigration attorney.
Who needs relocation and immigration tax planning?
- A professional moving from Pune, Bengaluru or Hyderabad to the Chicago suburbs on an H-1B, L-1 or a new green card.
- A Canadian on a TN or L-1 relocating to Naperville or Aurora, or a U.S. citizen moving from Illinois to Toronto.
- A U.S. green card holder or citizen planning to return to India or move to Canada.
- A family where one spouse moves first and the other follows later.
- Retirees changing country of residence while keeping pensions, property or investment accounts elsewhere.
What does a relocation plan cover?
| Direction of the move | U.S. questions we handle | Partner-country questions for your adviser |
|---|---|---|
| India to U.S. | Start of U.S. residency, first-year dual-status return, foreign account and PFIC reporting, ITIN for family | Indian residency status after you leave, conversion of resident accounts, remittance rules |
| Canada to U.S. | Start of U.S. residency, treaty tie-breaker, treatment of RRSP and TFSA, state taxes | Date you cease to be a Canadian resident, departure rules on assets, ongoing Canadian ties |
| U.S. to India | Dual-status departure year, expatriation rules if they apply, retirement accounts | Residency status in India, RNOR years, account re-designation |
| U.S. to Canada | Departure year return, citizenship-based filing if you are a U.S. citizen | Canadian residency start, newcomer reporting, foreign property reporting |
Our country checklists for moving from India to the U.S., moving from the U.S. to India and moving from Canada to India go step by step.
The three residency tests in one place
The U.S. substantial presence test needs at least 31 days in the current year and a weighted total of 183 days (all current-year days, one-third of last year's and one-sixth of the year before). A green card also makes you a U.S. resident. In a year in which you are resident for only part of the time, the IRS describes a dual-status year in which you file a return with a statement showing the other part.
Canada decides residency by residential ties. Significant ties are a home, a spouse or common-law partner and dependants in Canada, and secondary ties include bank accounts, a driver's licence and health insurance. A person who stays 183 or more days may also be a deemed resident, and a treaty can treat someone as a non-resident despite ties. India treats you as resident if you stay 182 days or more, or 60 days in the year plus 365 days in the four preceding years; Indian citizens who leave for work abroad are tested only on the 182-day rule, and visiting citizens or persons of Indian origin with Indian income above Rs 15 lakh use 120 days plus 365. See the comparison of residency tests.
How the engagement works
- Consultation. Ideally 6 to 12 months before the move. We collect target dates, visa type, family plans and asset lists.
- Written engagement agreement. It sets the scope of the plan, the returns included and the fee basis, and is signed before work starts.
- Document checklist. We list the records to gather in each country, plus the questions for your Canadian and Indian advisers.
- Preparation. We model residency dates, assets to sell or keep, and the filing calendar for the first two years.
- Review. You see a written plan with decision points and open questions.
- Execution. We prepare the arrival- or departure-year return and any information reports.
- Follow-up. We revisit the plan after the first return is filed.
Documents to prepare
- Immigration documents and a day-by-day travel record for the last four years.
- Statements for every bank, brokerage, retirement and provident-fund account, with balances on the planned move date.
- Property, mortgage and loan documents in each country.
- Employer offer letters, equity grants and any relocation payments.
- Prior-year returns from each country.
Common situations and fixes
- Selling assets after arriving. A gain on foreign property or shares sold after U.S. residency begins may be taxed in the U.S.; selling before may fall under the other country's rules. We compare outcomes.
- Keeping a home in the old country. A retained home and bank accounts can keep Canadian ties alive or affect Indian residency, so we document intent and facts.
- Leaving the U.S. The IRS says a covered expatriate is someone who meets certain thresholds: for 2025 an average annual net income tax above $206,000 for the five preceding years, a net worth of $2 million or more, or failure to certify five years of tax compliance on Form 8854. The mark-to-market exclusion amount for 2025 is $890,000. These rules apply to U.S. citizens who give up citizenship and to long-term residents who end their status.
- Moving money from India. Resident individuals may send up to USD 250,000 per financial year under India's Liberalised Remittance Scheme, per the Reserve Bank of India; NRI accounts follow different rules, so involve your CA.
A worked example
Daniel, a Canadian citizen on a TN visa, moves from Calgary to Aurora on June 15, 2026 and stays through December 31. Assuming no earlier U.S. stays that year, that is 200 days in the U.S. in 2026, so he meets the substantial presence test and becomes a U.S. resident from his first day of residence, making 2026 a dual-status year for the U.S. He keeps a Calgary rental property and an RRSP and TFSA. His Canadian CPA decides whether and when his Canadian residency ended, handles Canadian departure rules, and reports the rental as a non-resident. We prepare the U.S. dual-status return, review the treatment of the RRSP and TFSA, and check whether a treaty tie-breaker is needed if both countries claim him.
How we can help
From our Aurora, Illinois office we plan moves for people settling in Kane, DuPage, Will and Kendall counties and for those heading back to Canada or India. We handle the U.S. side and coordinate with your Canadian CPA or Indian CA so the dates and numbers agree. See individual returns for newcomers and NRIs, cross-border tax services and the U.S. residency tests guide. Our full list of services is on the services page.
Frequently asked questions
When does U.S. tax residency start if I arrive mid-year?
Generally on the first day you are present in the U.S. if you meet the substantial presence test for that year, or on the first day you are a green card holder in the U.S. We work the exact date out from your travel history.
Do I need to tell the IRS when I leave the U.S.?
Often yes, through a final-year return and, in some cases, Form 8854 for expatriation. We check whether your status triggers it.
Will leaving Canada trigger tax?
Canada has departure rules that can treat many assets as sold when you cease to be a resident. Your Canadian CPA applies those rules, and we coordinate the U.S. side.
Can you advise on my visa or green card?
No. We advise on tax consequences. For visa or green card questions you need an immigration attorney, and we are glad to coordinate.
How early should I start planning?
At least several months before the move date. Decisions about selling assets, closing accounts and choosing dates are hard to undo.
Official sources
- IRS: Substantial presence test
- IRS: Taxation of dual-status individuals
- IRS: Expatriation tax
- CRA: Determining your residency status
- Income Tax Department (India): Non-resident FAQs
- RBI: Liberalised Remittance Scheme FAQ
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.