All NRIs
What the country you are leaving can still tax, and for how long.

NRIWallah team
Updated September 2026 · 3 min read
Stopping being tax resident in another country does not always end what you owe there. And each country handles your departure differently, so advice from a friend who moved back from Toronto is of little use if you are leaving London.
The UK makes you wait. Your worldwide estate, Indian property included, stays within UK inheritance tax for three to ten years after you leave, depending on how long you were resident. Separately, if you come back to the UK within five years, gains made while you were away can be taxed on your return.
The US taxes by status, not residence. Citizens and green card holders are taxed on worldwide income and estates wherever they live, until they formally give up that status. For long-term green card holders, giving it up can trigger an exit charge.
Being taxable on worldwide income is not the same as paying US tax on all of it. Once you live in India, the foreign earned income exclusion takes up to $132,900 of earned income per person out of US tax for 2026, and the foreign tax credit usually covers much of the rest. The exclusion covers wages and professional fees but not pensions or social security, so retiring to India on a US pension is a different calculation from moving back mid-career.
Canada and Australia charge once, on the way out. Both treat most of your assets as sold at market value on the day you stop being resident, so you can owe tax on a gain without any sale to pay for it. After that, there is no continuing tail.
The UAE and Singapore charge nothing.
Canada lets you defer paying the departure tax by providing acceptable security to the Canada Revenue Agency, so the tax waits until you sell. Australia lets you choose to disregard the deemed sale altogether, but those assets then stay within Australian capital gains tax until you sell them or become resident again, and the choice covers all your assets, not a selection.
If you expect to sell soon, Australia’s choice only postpones the same bill. If you expect to hold for many years, it can matter a great deal.
Canadian real property and Australian real property are excluded from those countries’ departure taxes, but they stay taxable there whenever you sell, usually with tax withheld from non-residents at the sale. Property outside those countries, a flat in India included, is generally caught by the departure tax.
UK property stays within UK capital gains tax however long you have been away. A sale by a non-resident must be reported, and the tax paid, within 60 days of completion, separately from any tax return. Returnees who have not filed a UK return for years often miss this deadline and are fined.
US property also stays within US tax when sold by a non-resident, with withholding under FIRPTA.
Returning NRIs usually get two, sometimes three, financial years as resident but not ordinarily resident (RNOR), when most foreign income stays outside Indian tax. That is the natural time to sell foreign assets, but it rarely lines up with the other country’s rules: RNOR usually ends in year two or three, while the UK gains rule runs to year five and the inheritance tail can run to ten.
The RNOR tracker works out your Indian status, the DTAA estimator covers income taxed in both countries, and the inheritance and gift calculator shows what happens to your Indian estate while a tail is still running. For British NRIs who have kept an Indian domicile, the 1956 UK-India estate duty treaty can take Indian assets out of the inheritance tail altogether; that page explains the conditions.
Moving home is a taxable event in most countries — and they do it in completely different ways. Britain makes you wait out two clocks of different lengths. America follows your status, not your address, so leaving changes nothing at all. Canada and Australia charge you once, on the way out, on gains you have not realised. The Gulf and Singapore charge nothing. Pick where you live and the page reshapes around that regime.
Set to 0 if you have not gone yet, then increase it to see when each clock runs out.
years makes you a long-term resident, setting a tail — minimum three, rising by one for each year of residence beyond thirteen, capped at ten at twenty years or more.
Under ten of the last twenty tax years, so you never became a long-term resident. There is no tail to serve.
You are temporarily non-resident: sole UK residence in at least four of the seven tax years before leaving, and back within five. Anything you owned before departure and sell while away is taxed in the year you resume UK residence — not the year you sold, and at the rates in force when you return.
Assets you buy after leaving and sell while non-resident are outside UK CGT regardless.
| Years after leaving | Indian assets in IHT? | Gains follow you back? |
|---|---|---|
The two columns turn green at different times. That mismatch is the most common misunderstanding about leaving Britain.
There is no tail to wait out and no departure charge, because there is no departure. A US citizen or green-card holder remains taxable on worldwide income and their worldwide estate however many years they live in India. The only thing that ends it is formally giving the status up — and that is itself a taxable event.
On a work visa you are not a US person for these purposes. Leaving ends your exposure, apart from US-situs assets — which stay in charge on a $60,000 estate tax exemption, covered in the inheritance calculator.
But you are not taxed on all of it — the earned income exclusion is substantial
Being taxable on worldwide income does not mean paying US tax on all of it. Once you are living in India you will comfortably meet either the bona fide residence test or the 330-day physical presence test, and the foreign earned income exclusion then takes of earned income out of US tax for — per person, so a working couple can exclude between them. A foreign housing exclusion can sit on top.
It does not cover pensions. The exclusion applies to wages, salaries and professional fees — money paid for services you personally performed. The IRS expressly excludes pension or annuity payments, including social security benefits. So it shelters almost everything for someone still working, and nothing at all for someone retiring to India on a US pension. That is the single most important distinction on this page for anyone moving home at the end of a career.
Relief for what remains usually comes through the foreign tax credit and the India-US treaty rather than the exclusion — and the exclusion does not reduce self-employment tax. Claimed on Form 2555.
If you renounce or surrender the green card
A green-card holder is a long-term resident once they have held it in 8 of the last 15 tax years — you have , so . For covered expatriates, section 877A deems everything sold at market value the day before you go, with an exclusion of for 2025.
Reported on Form 8854. The rate used here is the long-term capital gains rate plus the net investment income tax; your actual mix of assets will differ.
treats you as having sold everything mobile at market value on the day you stop being resident, whether you sold it or not. There is no waiting period afterwards — pay it and you are done, which is a very different shape of problem from Britain's clocks.
The short-stay carve-out applies to you. You were resident for — inside the 60-month limit — so property you already owned when you arrived is outside the deemed disposition entirely. That saves roughly against a longer stay on the same assets. Anything you bought while resident is still caught.
You are past the short-stay carve-out. Had you left within 60 months of the 10 years before emigrating, property you already owned on arrival would have been excluded outright. At it is fully in charge.
Property is excluded. Real property in is not part of the deemed disposal — it stays taxable there on actual sale instead, whenever that happens.
You can defer the payment. Canada lets you elect to postpone the tax on the deemed disposition by posting acceptable security, so a paper gain does not have to be funded out of cash on the way out.
You can elect out entirely. An individual may choose to disregard the gain on all CGT event I1 assets. They are then treated as taxable Australian property until you actually sell or become resident again — so the choice defers the charge rather than cancelling it, and it is all-or-nothing across every asset.
Reporting is separate from paying: Form T1161 listing your property is required where the total market value exceeds , with penalties of CAD 25 a day for filing late.
charges no capital gains tax, no exit tax and no inheritance tax, so there is nothing to settle on the way home and no clock to wait out. Leaving is a genuinely clean break.
The catch is on the other side. Years in a zero-tax jurisdiction build no shelter for later: if you move on to Britain, America, Canada or Australia rather than to India, that country's rules apply to your worldwide position from the day you arrive. And if you are returning to India, your Indian tax residence resumes on a timetable of its own.
Returning NRIs usually qualify as Resident but Not Ordinarily Resident for two to three financial years, during which foreign income generally stays outside Indian tax. That window is the natural time to realise foreign gains — and it rarely lines up with whatever your departing country is doing. The RNOR tracker works out how long yours lasts.
Where income arises in both countries in the same year, the DTAA estimator covers which gets first claim. For what happens to your Indian estate, see the inheritance and gift calculator — and note that for British NRIs the 1956 UK-India treaty can remove the inheritance tail's effect entirely.
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Figures follow the revenue authorities directly — HMRC helpsheet HS278, IRS section 877A and Form 8854, CRA emigrant deemed disposition (forms T1161 and T1243), and ATO CGT event I1. Whether you are resident at all is decided by each country's own residence test, which turns on days, ties, homes and work rather than intention; this assumes you have already established that answer. Estimates only, and not advice.
Tell us which country you’re leaving and roughly when, and we’ll pass your request to an independent cross-border tax adviser (not part of NRIWallah) who can say which charge or clock applies first.
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