Executive Taxation, CXO Advisory & Cross-Border Equity Practice
Specialized tax architecture, foreign asset compliance, and confidential wealth controllership for Corporate CXOs, Tech Managing Directors, Senior Partners, and High-Earning Salaried Leaders. Navigating the 39% peak tax bracket, resolving NASDAQ/NYSE stock vesting liquidity mismatches, and ensuring zero-defect Schedule FA compliance under the Black Money Act, 2015.
High Cash Inflow. Peak Individual Tax Slabs. Zero Business Deductions.
Salaried leaders earning ₹2 Cr to ₹20 Cr+ shoulder India's highest marginal tax rate (up to 39% inclusive of surcharges) with virtually no expense deductions. Concurrently, unvested equity and cross-border stock grants create paper net worth that incurs heavy upfront cash perquisite taxes under Section 17(2), while minor reporting oversights in ITR Schedule FA invite flat ₹10 Lakh statutory penalties.
US RSU & Global Equity Architecture
Precision accounting for Restricted Stock Units (RSUs), Employee Stock Purchase Plans (ESPPs), and stock options. Reconciling fair market value (FMV) on vesting date against exercise price, managing cash tax flow, and executing cashless sale strategies.
Core Statutes: ITA § 17(2)(vi), Rule 3(8), Rule 3(9)
Schedule FA Zero-Defect Audit
Comprehensive reporting of overseas bank accounts (Table A1), custodial broker accounts (Table A2), vested shares (Table A3), and unvested stock options (Table B). Neutralizing the mandatory ₹10,00,000 flat non-reporting penalty per assessment year.
Penalty Protection: Section 43 BMA 2015 Relief
Foreign Tax Credit (Form 67) & DTAA
Claiming foreign tax credits on US withholding taxes (1042-S 25% tax) against Indian tax liabilities under Article 25 of the US-India DTAA. Preventing double taxation through timely Form 67 certifications before Section 139(1) deadlines.
Statutory Rule: Rule 128 Income-tax Rules, 1962
Executive CTC & NPS Restructuring
Structuring executive compensation packages with corporate employers: leveraging Section 80CCD(2) Corporate NPS (up to 10% of salary), Rule 3 motor car leases, and Section 17(2)(vii) superannuation caps to deliver ₹3L to ₹8L in annual tax savings.
Key Sections: § 80CCD(2), Rule 3(2)(A), § 17(2)(vii)
Angel Investing & Syndicate Tax Advisory
Advising executives investing in early-stage startups and Category I/II AIFs. Structuring Section 56(2)(viib) angel tax safe harbours, carried interest allocations, Section 54EE startup rollovers, and capital loss set-offs under Section 71.
Tax Arbitrage: Listed vs Unlisted Capital Gains
Board Directorships & Retainerships
Architecting the transition from salaried corporate roles into independent board directorships, venture partner roles, and private consulting. Optimizing retainers via Section 44ADA presumptive taxation or dedicated advisory LLPs.
Vehicle Options: Sole Prop § 44ADA vs Private LLP
The Employer Air-Gap Pledge: Absolute Workplace Privacy
We understand that senior corporate executives cannot have their personal investments, side-advisory retainers, overseas brokerage accounts, or family wealth disclosed to or scrutinized by their corporate employer’s HR or in-house payroll departments.
Executive Statutory Codex & Judicial Benchmark Matrix
| Statutory Reference | Domain | Practical Impact on Executive Wealth |
|---|---|---|
| Section 17(2)(vi) ITA | RSU / ESOP Perquisite | Taxed at fair market value on exercise/vesting date as salary perquisite, necessitating liquidity planning. |
| Section 43 Black Money Act | Schedule FA Penalty | Flat penalty of ₹10 Lakh per assessment year for non-disclosure of foreign shares, bank accounts, or trusts. |
| Rule 128 / Form 67 | Foreign Tax Credit | Mandates filing Form 67 before filing ITR to claim credit for US 1042-S withholding taxes against Indian tax. |
| Section 80CCD(2) ITA | Corporate NPS | Employer contribution up to 10% of salary deductible without standard deduction caps in both tax regimes. |
| Rule 3(2)(A) IT Rules | Company Car Lease | Caps taxable perquisite to ₹1,800/₹2,400 per month, converting substantial salary into tax-free conveyance. |
Schedule a Confidential Executive Review
Consultations are led directly by Fellow Chartered Accountants (FCA) with absolute discretion under the Chartered Accountants Act, 1949 and DPDP Act 2023.