Miles Education

2 MBA Degrees & an iMSA( STEM certified CPA:Degree  course) ACADs & placement teams . CCH Axcess Tax Process Administrator-Certified US GAAP & IFRS Certified,EA Certified,CWM,CISA,PMP,CPM,CTEP,CITA,CISSP,Digital Forensics Open University,Milton UK Certified
US CPA Exam Application & License in Progress,Black Belt Six Sigma,2 time Train the Trainer Certified(TTT)UK,London
Train for all- 1040,1041,990,1065,1120 ,706 ,709 & 1120S & respective State & International Tax laws & forms with corresponding US Accounting Standards.
Certified Forensic Accountant & Fraud examiner
part time mentor with Baruch University , Zichlin School of Business,NYC,US

US  Tax Manager(CPA Content Developer & Corporate US GAAP A/cing  &  Tax Law Lead Trainer)

EisnerAmper

(US CPA Licensed Firm)Partnership Real Estate Tax Accountant, Non-Monetary Transaction Accounting Exchanges (Mid Management Position).Part of Women's EA Chapter India US.

(Dy.) US Real Estate Property Partnership Tax Manager

MCNK Consulting Agency Inc.

Thorough learning and enjoy working with Maryanne and Scott for better learning and growth opportunities in Tax consultancy,tax technical legal interpretations etc.European & US international Tax Consulting,M/A,Foreign Partnership Tax Return Compliance & Tax Policy Research Interpretations' Article writing & blogs.

Tax Independent Consultant (Technical Writer)

Software Spinner Gmbh

Direct End Client Tax Resolution Services 
Privileged to work with an award winning(Global Mobility Rising Star of the Year 2019 for our Female CEO
Best Expat Tax Management Platform of 2019
Best US Expat Tax Return Solution of 2019
Shortlisted Most Innovative Use of Technology in Global Mobility of 2019
Shortlisted Tax Provider of the Year 2019)
FEATURED IN CNBC,US News,The American(Britain's Number 1 American Magazine & I am Expat) IT Solutions' company working to ease the life of so many individuals'  Tax compliance work for German Speaking Countries, corroborating their respective tax laws  in comparison to the US Tax Laws for Tax Treaty Analysis  & overall Return Preparation & E-Filing Work. I am honored to be working with CEOs & Managing Directors directly here who are themselves qualified ACCAs,EAs,US CPAs & Techonologically certified with world-class technology. Drake,TWIST,FreshDesk & LogIn AS tool usages.
Tax Reporting of the following :
Streamlined Filings & Voluntary Disclosure Programs(OVDPs)
PFICs(8621),CFCs(5471),Foreign Trusts(3520 & 3520A),FBARs(114),Tax Treaty Return position form 8833 and country totalisation agreement analysis. GILTI(8992),FATCA(8938),FEIE(2555),FTCs(1116),Domestic Individuals 1040s and respective forms and schedules and tax statements and Non Resident Forms like 1040NRs etc. With reference to IRS prominent Publications 54,514,519,551,550,17,463,535 etc.
Will conduct Tax  Return Reviews of 1500 to 2000 Returns with precision ,speed & operational excellence. Tax Returns prepared only from Client Interview Questions & AICPA & inhouse Tax organisers prepared, no SALY, along with impacts of the Tax Reforms impacted on the returns,form instructions, IRS Publications &  IRS Audit Technique Guides etc.

US Tax Advisor (Experienced Level) Reported to the Wein ,Vienna Office

PwC SDC Kolkata

Contributed in the Learning & Development (L & D) or Knowledge Management Team
for Tax Junior & Experienced Tax Accountants to assist in developing their expertise
Coordinated with Tax Managers & Directors from India & United States for developing &
restructuring the Tax knowledge materials like guidance on how to use organisers / checklists
for Tax Return Review through presentation guidance for training sessions etc. Preparation & Tax Compliance guidance given based on the Tax Regulatory Authorities, ethics for Tax accountants , ethical standards like Circular 230 , & AICPA Tax Codes & accounting standards with overall soft-skills professional development of employees.
Participated in Digital Upskilling programs as follows:
Qualified for & had been selected for the Digital Accelerator Program Wave 2 (Data Analytics
,Intelligent Process Automation, Artificial Intelligence: Machine Learning, Human- Centered
Design Programs) in September 2020. Qualified for Digital Acumen Knowledge Badge as per the Digital Quest Completions, Qualified and Certified Data Scientist. Assisted in Bot Creations for easing Tax Return Preparation work using the Robotic Process Automation(RPA) platform , the approved RPA tool platform being UiPath.
Tax Accounting & Compliance Work Tax Provision Calculations carried out as pe ASC 740,FAS 109 & IAS 12 using OIT(One Source Tax Provision software. Softwares in use OIT CTR(Corporate Tax Returns) & Go System RS Soft wares for processing Business Tax Return Forms. Abbyy Flexi-capture technical consultant(basic & advanced levels) for scanning documents  for structured & unstructured Data collection or Financial Records of the Client for accurate Return Preparations ; to implement a standardized procedure.
Usage of Inhouse Tools via training Mapper Tax Adjustments(runs through Machine Learning Coding), TRACK for K-1 Pass Through Entity Allocations etc. & Smart Review Tools which runs on python programming coding).

Assistant Manager (SA-2) Reported to the New York Metro Office (NYM)

KPMG GLOBAL SERVICES (KGS)

•Provide US  Tax compliance and advisory services to Federal / Domestic & Cross-Border /International Businesses like  Corporations & Pass-Through Entities-BEPS,BEAT,GILTI,FTCs etc.
(S Corporations, Partnerships & Hybrid entities like LLCs, LLPs etc.) for a variety of clients from Fortune 100 to emerging businesses.
•Work as part of a multi-disciplinary team helping to provide industry knowledge and experience
•Build and manage client relationships
•Manage teams of tax professionals and assistants working on client projects
•Advise clients and be responsible for delivering high quality tax service and advice
•Participate in and contribute to market and business activities external to the firm

Softwares handling Go-System RS by Thomson Reuters, CorpTax Corp Tax University, Internal Inhouse Softwares like Electronic Workpapers & Orion (Document Management System) ,US Sage/FAS 109 Depreciation Tool By Sage University,One Source Software  by One Source University.
Tax Research Tools for Tax Return Reforms etc. CCH Intellinet, SEC.com, Dun & Brad.
Usage of IRS Publications 541,542,334,3402,901,592,515 & other transaction related pubs

Industry catered to Real Estate & Telecommunication

Assistant US Business Tax Return Reviewer, (BTS East) reporting to New York City Office

Visionary Mindset Professionals & Management Development

Business Advisory Services offered in terms of Business Partnerships & Client Generation for the firm.
Managed to successfully partner with  IMA (Institute of Management Accounting) Dubai.

Business Advisor Reported to the Dubai UAE Office

Grant Thornton India LLP

[Tool-Go-System RS(Thomson Reuters' Product)] & 1099 Tracker for E-Filing                                                                                    
International Tax Practice Preparation & Compliance
Multi-State Tax Preparation & Compliance
Tax Resolution & Audits on a case to case basis.
Tax Accounting Methodologies as per Ethical Standards' Circular 230 & Accounting Standard 740
•	Tax Depreciation Accounting as per Tangible Property Rules
•	Tax Provisioning & Estimate Calculations/Quarterly Payments’ Calculations
•	Net Operating Losses for Corporations & Partnerships 
•	Book To Tax Adjustment Reconcilations (Schedule M-1 Adjustments)[Deferred Tax Calculations]
•	Alternate Minimum Tax(AMT) Calculations
•	Fund Tax Treatments (Partners’ Share Capital account basis calculation(Schedule K-1s) ,Passive-Foreign Investment Corporations(PFICs calculations & Tax Compliances) & Real-Estate Investment Trust Fund(REITs) Return Preparation & advisory.(Investments' Company Act,1940) Strong Knowledge
Accounting Income Tax Footnote Preparations & Disclosure-Accounting as per IRS Regulations

Industry Catered to small & medium enterprises from the Technology industry / arena

United-States Senior Tax-Consultant Reported to the Chicago Illinois Office

Internal Reveue Services

Attended Tax Workshops for Form 1040 & its respective schedules along-with the Site Coordinators workshops & Tax Ethics as prepared by IRS Experts for the Individuals belonging to Lower & Middle Incomed Groups as Volunteering Services as per Publication 4491 as slated mainly & was taught how to use the free prescribed filing & tackling the Software Tax Slayer Pro with Different Form Preparation Situations.

 Income Tax Assistant -Reviewer & Site Coordinator

Canada Revenue Agency - Agence du revenu du Canada

Attended Tax workshops at the CVITP was introduced in 1971 as a partnership between the Department of National Revenue (as it
was known then) and various community organizations. It was intended to ensure that all taxpayers
had equal access to the tax system.In 1988, the Canada Revenue Agency (CRA) established a partnership with Revenu Québec and volunteers from the province of Quebec, to have volunteers prepare both federal and provincial returns for eligible individuals.(Workshops Attended)
The CVITP is a source of pride for the CRA.
Types of returns prepared:
The CVITP assists taxpayers who have simple, non-complex tax situations. Volunteers do not prepare
returns for complex situations such as:
■ returns for deceased persons;
■ individuals who file for bankruptcy;
■ self-employed individuals;
■ individuals who report capital gains or losses; or
■ individuals who report employment expenses, or business or rental income and expenses. 
Commons Forms / Publications we use:
Form or Publications
5000-G General Income Tax and Benefit Guide
5000-R T1 General, Income Tax and Benefit Return
Schedule 1 Federal Tax
Schedule 2 Federal Amounts Transferred From Your Spouse or Common-Law Partner
Schedule 5 Details of Dependant
Schedule 6 Working Income Tax Benefit
Schedule 7 RRSP Unused Contributions, Transfers, and HBP or LLP Activities
Schedule 9 Donations and Gifts
Schedule 11 Tuition, Education, and Textbook Amounts
5013-G General Income Tax and Benefit Guide for Non-Residents and Deemed Residents of Canada
5013-R T1 General, Income Tax Return for Non-Residents and Deemed Residents of Canada
T778 Child Care Expenses Deduction
T1-M Moving Expenses Deduction
T1032 Joint Election to Split Pension Income
RC4064 Medical and Disability-Related Information
T2201 Disability Tax Credit Certificate
P105 Students and Income Tax
T4055 Newcomers to Canada
P110 Paying Your Income Tax by Instalments
T4114 Canada Child Benefits pamphlet
RC66 Canada Child Benefits Application

Community Income Tax Preparer (Voluntary-Services)

Certified in US Federal,Multi-State & International Tax Accounting,Tax Law & Data Analytics for Businesses & Individuals,TEFL(TR),TESOL(ASU)

Miss Nazneen Neville Motafram   is a strong IRS Qualified Tax Accountant, an AICPA Tax Technical Reviewer, Black Belt in operational six sigma excellence & Notary Public Officer from Department of Labor, Florida & Secretary of State specialized in Compliance, Tax Resolution, Tax Legal Research & Advisory Services who has participated in Leadership ideations for process excellence & overall Tax Business Line Improvements like introduction to Tax Resolution, Litigation Services, Tax Audits & Tax Controversy , Has also held seminars for end Clientele for E-B 5 Investment Visa Immigration & has provided Tax Compliance & helped in establishing businesses in the US, ongoing operations as well as closure of businesses as required. Filed yearly state annual franchise tax reports etc. directly as well. Mergers and Acquisitions and Corporate Restructuring work performed for clients.
US (Business & Personal Tax Accountant), Forms 1120 series (Corporation Series), Partnership Taxes 1065 & Personal Taxes, 1040 series, UK (Business & Personal) (CT 600 for Corporation Taxes & SA 100 for Personal Taxes), Tax Accountant (Forms & Canadian Personal Tax Accountant – Form T-1).
Experienced US Tax  AICPA Tax Technical Reviewer for business entities and individuals, skilled in technical software filings for federal, multi-state & international taxation accounting & compliance of IRS Code Treasury Regulations under the sub-chapters C-Corporations, S-Corporations, partnerships & individuals for workflow tools.
Contributed to Operational Excellence  in terms of Workflow developments like workpaper organizations using Excel Spreadsheets or Bots for various functionalities to reduce redundancies as well as improve efficiency in the Big Four for Tax Organisational Return work effectively and finally to Tax Learning & Development for freshers and experienced individuals alike.
Preparations, Reviews ,Tax Research & Tax Auditing conducted for Tax Returns using the IRS framed Form instructions.  Tax Codes (Treasury Departments), IRS Publications & Tax Audit Manuals alike, for that particular year of filing.
Personal Front: Attends Tax Reform Webinars & Workshops for better insights & listens & trained Western Classical Pianist from Trinity College, University of  London ,Guildhall , cleared till Grade 6 Practical Music , will pursue the Masters in Music in future; instrumental music at leisure. Avid Science Fiction  Reader. Worked with the best Fortune 500 Companies & Public Accountancy Firms like Deloitte , Grant Thornton & PwC(Price Water House Cooper) so far.

Nazneen N Motafram North American Tax Accountant MBA,MFP,iMSc Acctng. (UIUC),pursuing MSc Tax (TJU)

Oil and Gas Taxation (Including on mergers and acquisitions, farming out etc)
Mining Taxation
Value Added Tax
International Tax
Transfer Pricing 
Acte Uniforne OHADA
Code Général des Impots de la CEMAC
Code Douanier de la CEMAC
Negotiation of Production Sharing Contract (Contrat d'exploitation et d'exploration petroliere ou miniere)
Assisting Government for drafting of TP Legislation and Hydrocarbon/Mining Code

Ryan Allas

The Indian Supreme Court’s decision in the Tiger Global Mauritius case released today is a watershed moment for India-bound investment structures.

By allowing the Revenue’s appeal, the Court has made it very clear that treaty protection is driven by economic reality, not paperwork.

What makes this ruling even more significant is that the transactions were grandfathered under the India–Mauritius tax treaty — meaning they fell under the old regime that was supposed to be fully protected from capital gains tax in India.

Yet even in a grandfathered case, the Court has accepted that treaty benefits can be denied if the Mauritius entities are found to be mere conduits, with the “head and brain” of the investment sitting elsewhere.

Despite the Mauritius entities holding a valid Tax Residency Certificates (TRCs), a Category 1 Global Business Licences and Mauritian Resident Directors, this was still not enough to stop a deeper enquiry into beneficial ownership, control and substance.

For investors using Mauritius as a gateway into India, this is yet another reminder that a TRC is not a shield.A Mauritian company on paper is not enough and substance in Mauritius is what earns treaty protection.

That means:

-real decision-making in Mauritius

-real directors with independent judgment

-real commercial rationale

-real people, premises and operations

and real risk-taking at the Mauritian level


Without this, structures including  those set up years ago under grandfathering are increasingly vulnerable to being re-characterised by the Indian tax authorities.

I should add that I have not yet read in full the attached written judgment.

The SC of India has now openly endorsing a “look-through” approach.

At the same time, this is where policy matters.

It is now time for the Mauritian Government to actively leverage its special economic and diplomatic relationship with India to ensure that legitimate, substance-based Mauritius structures continue to receive the treaty certainty they were promised — and that Mauritius remains a credible and competitive international financial centre.

Those who have built real substance will continue to deserve treaty protection.
Those who relied on mailbox entities and rubber-stamp boards will not.

The era where a TRC alone could guarantee India–Mauritius treaty benefits is over.

#IndiaMauritius #TaxTreaty #Grandfathering #SubstanceOverForm #ForeignInvestment #MauritiusFinance #InternationalTax #DTAA #PrivateEquity #MAndA #TigerGlobal 

Johanne Hague Faraz Rojid Roomesh Ramchurn Dheerend Puholoo Feroz Hematally Antish Bissessur Shafeenaz Molotoo Ramgoolam Shameemah Abdool Rahman Darryl Sim Tanuja Appajala Anshee Sunnassee Medina T. 

https://lnkd.in/dEE52B4D

Ryan Dennis Allas

Tiger Global.Judgement

I am pleased to be participating in this webinar organised by Rogers Capital, alongside a highly prestigious and experienced panel of industry experts.
This promises to be an insightful discussion on the implications of the Tiger Global case and what it means for Mauritius as an International Financial Centre.
I encourage you to register and join us for this important conversation.

LIVE PANEL | Tiger Global Case: Implications for Mauritius as an IFC
Wednesday, 4 February 2026
2:00 p.m. (MRU Time)
The recent Indian Supreme Court judgment in AAR v/s Tiger Global Investments has sparked significant discussion across the global tax and investment community.
But what does this landmark decision really mean for foreign investors, cross‑border investment structures, and importantly — Mauritius as an International Financial Centre (IFC)?
Join our expert panel as we unpack the judgment from multiple angles, consisting of Ryan Dennis Allas, Pramod Kumar, Johanne Hague, Afsar Ebrahim and Iqbal Rajahbalee moderated by Shafeenaz Molotoo Ramgoolam.
This panel of seasoned professionals with deep expertise in international tax, treaty interpretation, fund structuring, and investment governance will offer key insights into the implications of the judgement and what it could mean for future investment into India through Mauritius.

Secure your spot and join the discussion: https://lnkd.in/djcKRxXW

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Nazneen N Motafram North American Tax Accountant MBA,MFP,iMSc Acctng. (UIUC),pursuing MSc Tax (TJU)

Ryan Allas

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Ryan Allas

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