USA · Service
Flip structures, holding companies and treaty-efficient ownership — the cross-border architecture that lets a business operate in both India and the US without tax leakage or FEMA surprises.
The hardest part of operating across India and the US is the structure that sits between them — where the holding company lives, how equity flows, and how the India–US treaty and FEMA both apply. We design ownership that satisfies investors, the IRS and the RBI at once, whether you are flipping a startup to Delaware or building an India–US group from scratch.
US or India holding layer chosen for investors, tax and exit.
Delaware flip of an Indian company with share-swap and valuations.
Outbound and inbound structuring aligned to RBI rules.
India–US treaty positions to reduce withholding and double tax.
Cross-border cap tables and option pools that work in both countries.
Structure built so a future acquirer or IPO needs no rework.
We map operations, investors and tax in both countries.
We choose the holding and ownership architecture.
We execute the flip or build with valuations and filings.
We reconcile FEMA, the IRS and your cap table.
We build the cross-border structure your US investor, the IRS and the RBI will each accept — designed once, not unwound at diligence.
Client identities withheld for confidentiality; outcomes described in general terms.
Share swap, valuations and FEMA reporting executed so a US raise could proceed.
US-ready holding structureIndia subsidiary and ownership aligned to the treaty and FEMA for a US parent.
Treaty-aligned India armBook a confidential consultation with our remote US Desk to architect an India–US structure that satisfies investors and both tax authorities.
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