DTAA & Tax Residency

Weighted total = current-year days + (days one year ago × ⅓) + (days two years ago × ⅙). You meet the Substantial Presence Test if that weighted total is at least 183 and you were present at least 31 days in the current year (IRC §7701(b)(3)).

Not modeled: "exempt individual" days (certain F/J/M/Q visa statuses don't count toward the test) and the closer-connection-to-a-foreign-country exception, either of which can change the real outcome.

Under Income Tax Act section 6, you're a resident if you meet Test A (present in India ≥182 days this financial year) or Test B (present ≥60 days this year — relaxed to 182 days for a visiting citizen/PIO not primarily here for other business — and ≥365 days across the preceding 4 financial years).

If resident, you're RNOR rather than ordinarily resident if you were non-resident in at least 9 of the preceding 10 financial years, or present 729 days or fewer in the preceding 7 financial years.

Not modeled: the Finance Act 2020 deemed-residency rule for citizens with no tax domicile elsewhere, and year-specific CBDT travel relaxations.

Estimates relief under the ordinary foreign tax credit method used by Article 25 of the India-US DTAA: the credit for foreign tax paid is capped at whichever is lower — the foreign tax actually paid, or the domestic tax otherwise due on that same income. Net additional domestic tax = domestic tax on the income − creditable foreign tax (floored at zero).

Not modeled: income-basket/resourcing rules, India's Rule 128 procedural requirements (e.g. Form 67 filing deadline), US Form 1116 category limitations, PFIC treatment of Indian mutual funds, or carryover of unused credit.