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ARCHITECT

Structural Tax Design & Regulatory Engineering

Structure determines outcome. We design the tax and regulatory frameworks that protect your global equity and optimize your cross-border footprint.

Key Components

International & US Cross-Border Taxation

  • Inbound & Outbound Strategy: Architecting tax flow for US entities with global parent / subsidiaries to minimize effective tax rates.

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  • Treaty Architecture (DTAA): Strategic application of DTAA to plan withholding taxes & prevent dual-taxation of global income.

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  • Global Disclosure Management: Specialized reporting for foreign-owned entities (Form 5472), intercompany transactions, & foreign bank/asset disclosures (FBAR/FATCA).

Transfer Pricing & Nexus Analysis

  • Inter-company Logic: Designing arm’s length pricing models & robust documentation for cross-border transactions.

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  • Permanent Establishment (PE) Risk: Proactive diagnostic reviews to identify & mitigate "accidental" tax triggers & jurisdictional exposure in new territories.

Individual Cross-Border Taxation

  • Cross-Border Individual Compliance: Preparation of US Form 1040 & Indian Tax Returns, ensuring unified disclosure of global assets.

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  • Residency & Treaty Tie-Breakers: Evaluation of tax residency status & using treaty tie-breaker rules to resolve dual-residency conflicts.

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  • Wealth & Estate Strategy: Designing a tax-efficient movement of personal assets, gifts, & inheritances across international borders.

Fractional CFO & Strategic FP&A

  • Advanced Financial Architecture: Setting up multiple  entities, intercompany accounts & consolidations, & real-time dashboards.

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  • Strategic Planning & Modelling: Building rolling 12-month forecasts & scenario sensitivity models to stress-test growth & hiring plans.

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  • Unit Economics & Growth Ops: LTV, CAC & burn rate optimization to ensure the business is prepared for funding rounds.

FEMA & Regulatory Strategy

  • Capital Flow Engineering: Structuring inbound (FDI) and outbound (ODI) investments to ensure seamless fund repatriation under FEMA and RBI guidelines.

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  • Regulatory Governance: Managing LRS (Liberalised Remittance Scheme) protocols, compounding applications, and mandatory reporting for cross-border capital movements.

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