Your Roth IRA is tax-free in America. Move back to India and India may tax what is inside it.

A Roth IRA, an HSA, a Canadian TFSA, the UK's 25% tax-free pension lump sum: each is tax-free because a specific foreign law says so. India has no equivalent concept and no obligation to honour someone else's exemption.

So the moment you become Resident and Ordinarily Resident again, India taxes your worldwide income, and the income inside these accounts comes into the Indian net. The wrapper that made them tax-free at home does not travel with you. Most returning NRIs never hear this until a CA raises it or a notice does.

This is the one where you should distrust a confident answer. There is no Indian ruling and no CBDT clarification on Roth IRAs, so two defensible positions coexist.

One view treats a Roth distribution as a pension under Article 20 of the India-US treaty, taxable only in the country where you live, which combined with its US tax-free status leaves little Indian tax. The weakness is that a Roth is not obviously a pension in the treaty sense, and that article really covers periodic payments.

The other, more conservative view is that India does not recognise the Roth character at all: once you are an ordinary resident it taxes the earnings as foreign income, and a lump-sum withdrawal falls under the treaty's other-income article, taxable in India with no US tax to credit against.

Neither is settled law. The right move is to take a clear, documented position with a CA before you file, not to assume the American answer is the Indian one.

The HSA is simpler and less kind. India has no health-savings concept, so once you are an ordinary resident the account is just an investment account in India's eyes. The interest, dividends and gains inside it are taxable here, usually as income from other sources at your slab rate, and the US rule that a qualified medical withdrawal is tax-free buys you nothing on the Indian side.

It is also a foreign asset, so it belongs in Schedule FA of your return every year once you are an ordinary resident, with the Black Money Act penalties that ride on getting that wrong.

Section 89A is the provision people reach for, and it is genuinely useful, just not for the accounts in this article.

What it does is fix a timing mismatch. India taxes a foreign retirement account as it grows; the foreign country taxes it only on withdrawal. Left alone, you can be taxed in both countries in different years. Section 89A, claimed with Form 10EE in your first year as an ordinary resident, lets you defer the Indian tax to the year the foreign country taxes the withdrawal, so the two line up.

The limits are the point. It covers accounts in three notified countries, the US, the UK and Canada, and only accounts the foreign country taxes on withdrawal, a traditional 401(k), IRA, RRSP or SIPP. A Roth IRA and an HSA are never taxed on withdrawal at home, so there is no foreign tax to align to and 89A does nothing for them. And it is deferral, not exemption: it changes the timing, never makes the income tax-free. Form 10EE also cannot be filed late, so the first ordinary-resident year is the one that counts.

Here is the move that is not ambiguous. For the first two to three years after you return, you are usually Resident but Not Ordinarily Resident, and during that window foreign income is not taxable in India at all.

So the reliable plan is to realise, draw down or reorganise these accounts while you are still RNOR, before the ordinary-resident taxation switches on. One precision that catches people: the money must be received into your foreign account, not an Indian one. Foreign income first received in India loses the RNOR exemption.

This is the same window that shields the rest of your foreign income on return, and it closes on its own schedule, so the accounts you most want to clean up are worth sequencing early.

The reason this needs a person and not a rule of thumb is that half of it is judgement, not arithmetic. The Roth position is contestable, the HSA and TFSA are taxable but need correct Schedule FA reporting, 89A helps some accounts and not others, and the RNOR window is a timing decision you get one shot at.

A CA who does returning-NRI work maps each account to how and when India will tax it, files Form 10EE where it helps, sequences withdrawals into the RNOR window, and takes a defensible Roth position in writing. That is the difference between a clean transition and a notice two years after you thought you were done.