Santanu B.

IRS Enrolled Agent (EA) | Ex-Big 4 US Tax Manager with 19.5 years of overall financial experience and 15 years of specialized expertise in US Taxation. I partner with non-US founders, cross-border startups, real estate investors, private equity fund managers, non-profits, and US CPA practices to deliver high-level tax structuring, compliance, and strategic advisory. Having held Tax Consultant through Managerial roles across Deloitte, EY, PwC, and RSM, I bring institutional-grade technical knowledge, modern AI-assisted workflows, and direct workflow leadership without full-time executive overhead. Whether you need foreign-owned LLC compliance, S-Corp filings, PE/FoF distribution waterfall structuring, 501(c)(3) exemption applications, or CPA firm overflow support, I deliver precise, audit-ready solutions. 🛡️ Client Data Safeguard & Confidentiality: Strict compliance with IRS Section 7216 data privacy standards and IRS Security Summit guidelines. All files processed using bank-grade encryption protocols and strict NDAs to guarantee 100% data protection. Core Areas of Technical Mastery: ##1. Foreign Inbound Entities, Blockers & Non-Resident Aliens (5472 / 1120 / 1120-F / 1040-NR) • Foreign-Owned LLCs & Blockers: Tax classification, Form 1120-F corporate blockers, ECI modeling, FIRPTA withholding mitigation, late-filing penalty abatement, and multi-year compliance cleanup for non-US owners (Forms 5472, 1120, 1120-F). • Non-Resident Aliens (1040-NR): Form 1040-NR, Schedule E rental operations, IRC § 871(d) real property income elections, FDAP vs. ECI, and tax treaty positioning. • Disclosures & Treaties: FBAR (FinCEN 114), Schedule B, Form 8938 (FATCA), Form 8865, 3520/3520-A, withholding tax (1042/1042-S), and Subpart F / GILTI impact checks. ##2. Private Equity, Fund of Funds, Real Estate & Partnerships (1065 & 1120-S) • Fund of Funds & PE (1065): Form 1065, Form 8825, and Schedule K-1/K-3 investor reporting for FoF, multi-tier real estate, and PE fund structures ($60B+ AUM experience). • Waterfalls, Carried Interest & Fees: Multi-tier distribution waterfalls (American & European models), carried interest (IRC § 1061 3-year rule), clawbacks, GP management fee offsets, fee waivers, and Section 709 syndication expenses. • Blockers, REITs & Interest Limits: Corporate blocker integration (1120-F), Form 1120-REIT testing, Section 163(j) interest limitations, and Real Property Trade or Business (RPTOB) election trade-off modeling. • Allocations, Basis & Capital Recovery: Section 704(b) capital accounts, Section 754 adjustments, Section 743(b)/704(c) allocations, Section 179, bonus depreciation, cost segregation integration, and Historic Tax Credits. • S-Corporations (1120-S): Form 2553 elections, reasonable compensation, shareholder basis, distributions, and 1120-S preparation. ##3. Exempt Organizations & Non-Profits (990, 990-T & 1023) • Tax-Exempt Status: Form 1023 / 1023-EZ applications to secure 501(c)(3) federal recognition. • Compliance & Private Foundations: Form 990 and Form 990-PF processing for private foundations, minimum distribution calculations, and excise tax planning. • UBTI & State Exemptions: Unrelated Business Taxable Income (UBTI/UBIT), Form 990-T reporting, and multi-state corporate/property tax exemption filings. ##4. Private Wealth, Fiduciary & Gift Taxation (1040, 1041, 709) • Gift & Wealth Transfer: Form 709 (Gift & GST Tax), lifetime credit utilization, split-gift elections, and valuation reporting. • Fiduciary Income Tax: Form 1041 for complex/grantor trusts and decedent estates (DNI and FAI calculations). • HNW & Multi-State: Multi-state tax (SALT) allocation and complex tax planning for fund founders, executives, and family offices. Software & AI Technology Ecosystem: • Tax Software: CCH Axcess, CCH ProSystem fx, GoSystem Tax RS, ONESOURCE, UltraTax CS, Drake, CaseWare. • AI & Research Platforms: Enterprise CoPilot, Blue J AI, Bloomberg Tax (BNA), SurePrep, K-1Suite, PartnerSight, PartnerForms, Power BI. • Data Security: IRS Section 7216 Compliant, Bank-Grade Encryption, Strict Confidentiality & NDA Standards. Engagement Models: • Direct Consulting: Structuring, blocker/UBTI strategy, and filings for non-US founders, S-Corps, DTC e-commerce brands, private funds, and non-profits. • CPA Subcontracting & Overflow: Complete technical review of 1120-S, 1065, 1120-F, 1041, 1040, and 990/990-T packages under your firm's EFIN during peak deadlines. IRS Enrolled Agent (EA) | Authorized Paid Preparer | Available for immediate project onboarding.