Jurisdiction: US

Every investment, acquisition or business restructuring presents an opportunity to create long-term value and carries tax and regulatory consequences. The choice of ownership structure, investment vehicle and operating model can influence financing flexibility, future expansions, succession planning and eventual exit strategies.

We advise businesses, promoters, investors and family offices on designing commercially efficient structures that align tax, regulatory and business objectives across multiple jurisdictions while remaining adaptable as businesses evolve.

Transactions and Structuring

Mergers, Acquisitions, Reorganisations & Divestments
Business transactions require careful consideration of commercial, tax and regulatory implications. We advise on structuring acquisitions, reorganisations, and divestments so execution is clean and the structure still serves the business well after the deal closes.

Entity Selection & Capital Structuring
Selecting the appropriate legal entity and funding model is fundamental to an efficient international structure. We advise on entity selection, financing arrangements and profit repatriation that align with business and tax objectives.

Transaction Tax & Cross-Border Tax Advisory
Cross-border transactions often trigger tax implications across multiple jurisdictions, requiring careful coordination of domestic tax laws, tax treaties and regulatory requirements. We advise on evaluating the tax consequences of investments, business transfers and cross-border reorganisations to support commercially efficient and tax-effective transaction structures and assess FIRPTA where US real property is involved.

How We Work

Cross-border transactions require more than tax advice. We bring together the US, UAE, India and other jurisdiction considerations into one coordinated strategy, helping businesses execute transactions that stay commercially practical and tax efficient, with any US reporting kept consistent with the structure and coordinated with your return preparers.

International tax rules continue to evolve as businesses, investments and families become increasingly global. Cross-border structures often involve multiple tax systems, treaty provisions and anti-deferral rules that require careful interpretation beyond the domestic tax laws of any one jurisdiction.

We advise clients on complex international tax matters affecting cross-border investments, business operations and private wealth. Our focus is on providing practical, commercially aligned advice that supports informed decision-making across the United States, India, the UAE and other jurisdictions.

Treaty and Tax Advisory

Tax Treaty & Residency Advisory
International tax treaties and residency rules can significantly influence the taxation of cross-border income and investments. We advise on treaty interpretation, residency analysis, source, the foreign tax credit, withholding, and eligibility for treaty benefits across multiple jurisdictions.

International Anti-Deferral Regimes
Cross-border structures can pull in anti-deferral rules such as CFC, Subpart F, PFIC, and net CFC tested income (NCTI, the renamed GILTI regime), which can tax foreign earnings before any cash is distributed. We advise on what is caught, the elections available, including QEF and mark-to-market for PFIC holdings, and on restructuring to step outside a regime where that is possible.

Permanent Establishment & Cross-Border Business Taxation
Expanding into a new country can create tax obligations beyond the country of incorporation. We advise on permanent establishment exposure, business presence, and operating models that support international expansion without an unintended tax footprint.

International Tax Reviews & Regulatory Advisory
A structure should move with the law and the business. We review existing structures against the current rules, the treaties, and the post-2025 changes, including the NCTI and FDDEI redefinitions, identify exposures, and provide technical positions that support cross-border decisions.

How We Work

Every cross-border tax issue is read in its wider international context, weighing how domestic law, treaties and regulation interact. The work is partner-led: positions are stress-tested against the current rules, including the post-2025 changes, before we commit, with any US reporting kept consistent with the advice and coordinated with your return preparers.

The US federal estate tax applies to the worldwide assets of US citizens and domiciliaries, and to the US-situs assets of non-resident aliens, at a top rate of 40% above the exemption.

For families with US connections the exposure is real. We work with business owners, founders, family offices and high-net-worth families on transferring wealth efficiently across generations, bringing the US estate and gift position together with the India, UAE and other jurisdiction positions into one plan.

Planning and Structures

Estate, Gift & Generation-Skipping Transfer (GST) Tax Planning
How wealth is transferred can significantly influence long-term tax outcomes. We look at the estate, gift and GST position together, covering lifetime gifting, exemption use, and ownership models that move wealth to the next generation in a way that supports the wider plan rather than one gift at a time.

Cross-Border Succession Strategies
Where assets, businesses and beneficiaries span multiple jurisdictions, succession planning requires careful coordination. We help develop succession strategies that align ownership continuity, family objectives and international tax considerations while addressing the interaction of different legal and tax systems.

Family Trusts, Foundations & Wealth Holding Structures
Trusts, foundations and family holding structures can play an important role in wealth preservation and succession planning. We advise on evaluating appropriate ownership structures by considering governance, flexibility, tax implications and long-term family objectives across jurisdictions.

US-Situs Asset Planning for Non-US Persons
Ownership of US real estate, securities and other US-situs assets may create significant estate tax exposure for non-US persons, and the allowance available to them is small. For international investors and Indian-origin families, we advise on ownership models that balance the investment objective, succession, and the income tax and FIRPTA consequences, so the answer works overall rather than for one tax alone.

How We Work

We help families build ownership structures that continue to work as assets grow, jurisdictions change and wealth passes across generations. Engagements are partner-led, with the estate, gift and income tax angles taken together rather than separately, and any reporting kept consistent with the structure and coordinated with your return preparers.

Moving across borders can change how income, investments and wealth are taxed, often substantially. The decisions that matter most are usually the ones taken before US tax residency begins, or before US status is given up, because once the date passes most of them cannot be reversed.

We work with entrepreneurs, executives, investors and globally mobile families on planning the move in both directions, looking at residency, asset ownership, business interests and succession together so the position stays efficient through the transition.

Mobility Planning

Pre-Immigration Planning
The period before becoming a US tax resident offers the most valuable planning opportunities. We review investments, ownership structures and wealth arrangements ahead of the move, addressing PFIC exposure (including many Indian mutual funds and ETFs), basis planning, and estate and gift tax considerations before worldwide assets come within the US tax net.

Expatriation & Exit Planning
For US citizens and long-term green card holders giving up their status, the expatriation tax under Section 877A can treat worldwide assets as sold the day before departure. We work through covered expatriate status and the steps that manage the charge, well ahead of the date.

Residency Planning & Cross-Border Mobility
US tax residency can turn on how many days are spent in the country, and people cross into it without meaning to. We advise on managing residency status, including the substantial presence day-count, the closer connection position, the treaty tie-breaker, and the timing of a residency that starts or ends mid-year.

International Wealth & Business Transition
International relocation frequently affects both personal wealth and business interests. We advise entrepreneurs, business owners and family offices on aligning ownership, succession and investment structures with their evolving international footprint.

How We Work

This work is built around timing, because the useful steps sit before US residency begins or before status is given up. We plan the move in both directions and keep residency, ownership and business interests on one timeline, partner-led from the first conversation. We keep any US filing obligations aligned with the overall plan and coordinated with your return preparers.