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India
United States
Cross-border
The gap

Generic AI gives you information.
You need a strategy.

You ask for the play. You get a recitation of the law. The court ruling doesn't exist. The treaty article is paraphrased — and wrong. The statute citation is from a repealed section. The agency notice was superseded two years ago. Generic AI tools summarize. They don't verify across precedent, the treaty network, the statute book, or the agency-guidance stream — the four pillars a real cross-border memo has to stand on.

Taxentra was built to close that gap.

Capabilities

What Taxentra delivers.

Built for finance professionals handling complex tax work. Not a chatbot. A strategy engine.

Strategies, not summaries

Every response opens with monetary exposure or the structural play. Stacked risk detection. Alternatives compared in tables. Like a senior partner — not a textbook.

Every citation verified

4,709-entry authority database spanning court rulings, the cross-border treaty network, statutes & regulations, and agency guidance — verified against Supreme Court, CBDT, CBIC, RBI, IRS, Indian Kanoon, and US Tax Court. Zero hallucinated case names.

Multi-jurisdictional

US federal and SALT. India direct tax and GST. Cross-border DTAAs. Transfer pricing. FEMA structuring. All analyzed simultaneously, not sequentially.

Document analysis

Upload notices, returns, Form 16, 26AS, W-2s, financials. Taxentra reads them and flags missed deductions, compliance gaps, planning opportunities.

Client-ready advisory export

One click generates a professional advisory memo — executive summary, numbered analysis, risk matrix, compliance checklist, and verified citations. Downloads as Word or PDF, ready for your engagement file.

Live research

Searches 15+ official databases in real time before every citation: e-SCR, Indian Kanoon, CBDT, CBIC, RBI, IRS, and US Tax Court. Verification links included.

How it works

From question to strategy.
In 30 seconds.

Describe the situation. Taxentra does the rest.

01

Describe the situation

Entity structure. Amounts. Jurisdictions. The goal. The more specific you are, the sharper the strategy. Upload documents for deeper analysis.

02

Get the analysis

Taxentra searches verified sources, computes exposure, identifies cascading risks, presents structural alternatives, and commits to a recommendation.

03

Deliver the work

Download as Word or PDF. Drop the client-ready strategy into your advisory letter. Hand the document checklist to your client.

Client-Ready Advisory

From conversation to client deliverable.

Run your analysis, ask your follow-ups, refine the strategy. Then one click turns the entire conversation into a polished advisory memo — synthesized, structured, and ready for your engagement file. Scroll through a real example below.

Executive summary Footnoted citations Risk matrix Structural alternatives Compliance checklist Firm-grade cover page
By a Finance Professional. For Finance Professionals.
STRATEGIC TAX ANALYSIS
ESOP / RSU Taxation
Indian Resident with NASDAQ RSUs
Complete Tax Treatment with FTC, DTAA & Schedule FA
Client
Mr. Rajesh Sharma
Matter
Cross-Border ESOP/RSU · India-US DTAA
Date
28 May 2026
Via
Taxentra AI Strategy Engine
1.Executive Summary
TOTAL ESTIMATED EXPOSURE
₹85 – 115 Lakhs combined perquisite + capital gains
  1. RSU taxation occurs at two stages: salary perquisite at vesting under S.17(2)(vi) at slab rates, and capital gains at sale under S.112A / S.111A.
  2. FMV must be computed tranche-wise: NASDAQ closing price on each vesting date × SBI TT buying rate. Averaged pricing is the most common reassessment trigger.
  3. DTAA Article 15 applies — US taxes paid are eligible for FTC under S.90/90A, but Form 67 must be filed BEFORE the ITR due date.
  4. Stacked risk: Missing Schedule FA triggers ₹10L penalty under the Black Money Act AND extinguishes DTAA relief on the same income.
RECOMMENDED ACTION
File Form 67 immediately → Compute FMV tranche-wise → Claim FTC → Disclose in Schedule FA. Execute in this priority order.

2.Taxation at Vesting — Salary Perquisite

When restricted stock units vest, the fair market value of shares on the vesting date is treated as a perquisite under Section 17(2)(vi) and taxed at the individual's applicable slab rate — for this exposure range, 30% plus surcharge and cess.

Where the employer is a US corporation with no Indian payroll presence, the employee bears the obligation to self-assess, pay advance tax under S.208/209, and report in Schedule S of the ITR.

Section 17(2)(vi), Income Tax Act, 1961 — perquisite value of specified securities allotted by the employer.
Rule 3(8)(iii), Income Tax Rules — FMV = closing price on a recognized exchange on the exercise date.
2.1FMV Computation Methodology

The FMV must be computed tranche-wise — each vesting lot carries its own date, price, and forex rate. Using a single averaged price is incorrect and triggers reassessment under S.148A.

2.2Foreign Tax Credit — Form 67

Where US federal tax was withheld on the perquisite, the resident may claim FTC under S.90 read with DTAA Article 25. Form 67 must be filed electronically before the S.139(1) due date — late filing results in permanent denial with no condonation.

Rule 128(9), Income Tax Rules — Form 67 to be furnished on or before the return due date.

3.Risk Assessment
Risk FactorLikelihoodExposureAction
Form 67 not filed before ITR due dateHIGH₹15–25LFile immediately
Schedule FA non-disclosureHIGH₹10LDisclose all foreign securities
Incorrect FMV — averaged vs tranche-wiseMEDIUM₹2–8LRecompute per vesting lot
Advance tax shortfall — S.234B/C interestMEDIUM₹0.5–2LPay in quarter of vesting
DTAA denied on reassessmentLOW₹10–20LMaintain W-2, 1042-S, returns
4.Structural Alternatives
DimensionA: Sell at VestB: Hold & Sell Later
Capital gainsNil — sold at FMVLTCG 12.5% / STCG 20%
FTC utilizationFull, in vesting yearCarry-forward; expiry risk
Currency riskNil — immediate INRUSD/INR exposure
Verdict✓ Preferred for >₹50LOnly on >25% conviction

5.Authorities Cited
  • 1.S.17(2)(vi), Income Tax Act, 1961 — Perquisite value of specified securities
  • 2.Rule 3(8)(iii), Income Tax Rules — FMV computation for listed securities
  • 3.S.90 / 90A, Income Tax Act — FTC under bilateral treaties
  • 4.Rule 128, Income Tax Rules — Form 67 procedure and deadline
  • 5.India-US DTAA, Article 25 — Elimination of double taxation
  • 6.S.43, Black Money Act, 2015 — ₹10L penalty for Schedule FA default
6.Compliance Checklist
EMPLOYEE — SELF
Compute FMV tranche-wise (NASDAQ close × SBI TT rate per date)
File Form 67 electronically — before ITR due date under S.139(1)
Complete Schedule FA and Schedule FSI
Claim FTC in ITR under the correct income head
TAX ADVISOR — VERIFICATION
Verify FTC does not exceed Indian tax on doubly-taxed income
Confirm no PFIC implications; verify cost basis = FMV at vesting
DISCLAIMER

This advisory memo was generated by Taxentra. It is provided for professional reference only and does not constitute legal or tax advice. All figures are estimates; verify current provisions before advising clients. © 2026 Taxentra · taxentra.ai

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Why Taxentra

Taxentra vs. generic AI.

CapabilityTaxentraGeneric AI
Court rulings & precedents — Indian SC/HC/ITAT + US federal courts✓ 466 verifiedFrequently invents cases
Cross-border treaty network — DTAA articles, article-by-article✓ 280 verifiedParaphrased / misquoted
Statutes, regulations & forms — ITA 2025, IRC, GST, state rules, forms✓ 896 verifiedOften cites repealed sections
Agency guidance & circulars — CBDT/CBIC circulars + IRS Notices/RPs/RRs/TDs✓ 3,067 verifiedMisses superseded items
Stacked risk detection✓ Shows cascading failuresLists risks independently
Structural alternatives compared✓ 2-3 options across 7 dimensionsInconsistent
Document checklist (split by provider)✓ MandatorySometimes
Client-ready strategy memo✓ Every response · Word/PDFNot standard
Professional advisory export✓ Synthesized memo with risk matrixNot available
Cross-border completeness (FIRPTA, §367, §1446)✓ Mandatory for cross-borderOften missed
Form-filling guides with download✓ Field-by-fieldText only
Treaty article-wise analysis✓ Deep, article-specificSurface level
Source URLs for verification✓ MandatoryInconsistent
Arithmetic accuracy✓ Step-by-step verifiedFrequent calculation errors
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About the founder

Built by a practitioner.

Saurabh Gupta is a finance professional and the founder of Taxentra. He built this tool after watching talented professionals across firms — CAs, CPAs, CFOs, tax partners — spend their best hours chasing citations and assembling memos instead of doing strategic work.

"I built the tool I wished existed — for everyone. A strategy engine for the moments that demand real analytical depth."

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