Premium Boutique Advisory

Cross-Border Structuring for India–U.S. Businesses

We design and execute compliant financial structures for companies moving capital between India and the United States — built by CAs and CPAs, backed by documentation.

Request Private Consultation → Evaluate Your Structure
Modern architecture representing international business
DTAA
Treaty-aligned structuring
Compliant structures, reviewed and defensible across both jurisdictions.
— Built by CAs & CPAs
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Tax-efficient
Structural clarity and tax efficiency for India–U.S. operations.
Treaty-aligned
Work positioned around treaty provisions and disciplined implementation.
Fully defensible
Structures that can be reviewed and defended over time.
Who We Work With

Serious businesses with cross-border complexity.

We work with
U.S. companies owned or operated by Indian founders Indian businesses receiving payments from U.S. clients Trading, SaaS, consulting & service businesses Companies with ₹5 Cr+ / $500K+ annual cross-border flows
We do not work with
  • Individuals seeking personal tax avoidance
  • Small or one-off transactions
  • Undocumented or aggressive tax positions
What We Do

Structuring, execution & oversight for serious businesses.

Advisory team professional meeting
"Cross-border transactions are not just about moving money — they are about structuring it correctly."
01 — Cross-Border Structuring

Cross-Border Structuring

We design transaction and entity structures aligned with applicable regulations and treaty provisions, including the India–US Double Taxation Avoidance Agreement.

02 — Execution & Implementation

Execution & Implementation

We don't stop at advice.

  • Documentation and agreements
  • Withholding positioning (W-8 series and related forms)
  • Payment structuring and routing
  • Coordination with accountants and institutions
03 — Ongoing Oversight

Ongoing Oversight

As your business evolves, so should your structure.

  • Continuous compliance alignment (India & U.S.)
  • Adjustments based on scale and operational changes
  • Audit-ready documentation and support
How We Work

A refined process for evaluating and implementing structure.

01
Assessment
We analyze your current structure, residency position, and transaction flow.
02
Structuring
We design a compliant, treaty-aligned framework tailored to your business.
03
Documentation
Every structure is backed by proper agreements, filings, and defensible reasoning.
04
Execution Support
We assist in implementing the structure end-to-end.
Our Approach

Compliance-first, by design.

What we do

  • Every structure designed within applicable laws in India and the United States
  • Rely on treaty provisions, regulatory frameworks, and documented positions
  • Prioritize long-term defensibility over short-term gains

What we don't do

  • No aggressive tax evasion strategies
  • No undocumented or artificial arrangements
  • No misuse of treaty provisions

Professional Backing

  • Chartered Accountants (India)
  • Certified Public Accountants (U.S.)

Every engagement is supported by structured analysis and documentation suitable for professional review.

Pricing Philosophy

Performance-aligned & engagement-specific.

We operate on a performance-aligned model. Our fees are typically linked to the value created through structuring and optimization, ensuring alignment with our clients.

Each engagement is customized based on:

Complexity Structure, entity footprint, and technical requirements.
Jurisdictional considerations India, the U.S., and related compliance layers.
Volume of cross-border transactions Materiality and recurrence of fund movement.
Professional office with city view
Engagement-specific
Case Studies

Premium, defensible case positioning.

Each case is presented as a specific fact pattern with a defined challenge, approach, and outcome.

Case Study 01

Cross-Border Trading Structure Optimization

Client Profile

U.S.-incorporated trading company operated by Indian founders.

Challenge

The client faced inefficient tax treatment and potential exposure in India due to structure misalignment on significant cross-border trading income.

Approach
  • Detailed analysis of operational control, transaction flows, and tax residency
  • Applied provisions of the India–US Double Taxation Avoidance Agreement
  • Structured income characterization per Indian tax regulations
  • Implemented a defensible framework with agreements and filings
Outcome
  • Optimized tax treatment on ₹3 Cr+ in cross-border income
  • Eliminated avoidable tax exposure through compliant structuring
  • Established a fully documented, audit-ready position
Case Study 02

Cross-Border Payment Structuring (U.S. to India)

Client Profile

U.S. company with Indian ownership and operational linkages.

Challenge

The client needed to transfer funds to an Indian partner entity without triggering unnecessary withholding or adverse tax consequences.

Approach
  • Designed transaction structure aligned with treaty provisions
  • Ensured proper classification of payments and supporting agreements
  • Coordinated U.S. and Indian compliance requirements
  • Documented the entire framework for defensibility
Outcome
  • Enabled efficient cross-border fund movement
  • Reduced unnecessary withholding and tax friction
  • Maintained full compliance across both jurisdictions

Each case reflects a specific fact pattern. Outcomes depend on individual circumstances, applicable laws, and regulatory interpretation.

Get in Touch

If your business operates between India and the U.S., your structure matters.

Request a private consultation to evaluate your current setup.

Request Private Consultation → Evaluate Your Structure
WhatsApp
+91-9997230108
Email
info@usdmerchant.com
Address
Connaught Place, New Delhi, India 110001
LinkedIn
linkedin.com/company/usdmerchant
Facebook
https://www.facebook.com/USDMerchant
Hours
10:00 am – 5:00 pm, Mon–Fri