Every case study in this series shares the same underlying process once the residency question and the non-willfulness question are settled. Here's what actually needs to be assembled.
1. Full account inventory, going back at least 6 years. Every NRE, NRO, FCNR, PPF, mutual fund, insurance-linked investment, and any account where you or a family member has signature authority — even joint accounts you don't actively manage, even accounts closed years ago.
2. Highest year-end balance for each account, each year. This is what the SDOP 5% penalty (if applicable) is calculated from — a single number per account, per year, at year-end, not a running average.
3. Income documentation for the 3 most recent filing years. Interest certificates, mutual fund capital gains statements, rental income and expenses, salary if applicable, and any business or professional income earned in India.
4. Foreign tax paid documentation. TDS certificates, Indian tax returns filed, and challans — this is what supports the Foreign Tax Credit claim that typically reduces or eliminates the incremental US tax bill.
5. Entity ownership check. Any Indian company, LLP, or partnership where you hold a qualifying stake needs a separate look for Form 5471 or similar entity-level reporting — this is the piece most self-prepared filings miss entirely.
6. A specific, honest written account of why the filings were missed. Not a template. The actual sequence of events — what you knew, when, and why the gap happened — is the backbone of the non-willfulness certification.