Sofia Eriksen Bhandari — International Tax Counsel, Cross-Border Equity

Sofia practices cross-border individual tax, with a concentration on equity compensation for employees who work across two or more jurisdictions during a single vesting cycle. Her client base is weighted toward US tech companies with engineering offices in London, Tel Aviv, Toronto, and Berlin, where the outbound and inbound secondment patterns produce sourcing problems that neither the US nor the host country wants to resolve neatly. She has argued treaty positions under the US-UK and US-Canada treaties more times than she has counted.

The case she sees quarterly is the trailing-source RSU. A senior engineer granted 20,000 RSUs while based in the San Francisco office, vesting over four years, relocates to the London office 18 months into the vest. The remaining 12,500 shares vest while the client is UK tax resident, but the IRS sources the income on a workdays-in-US basis measured across the full vesting period. Roughly 37.5% of the vesting value remains US-source ordinary income for US-resident years, with HMRC simultaneously asserting UK residence taxation on the full vest. Sofia files the treaty claim, coordinates with UK counsel on the PAYE withholding, and builds a foreign-tax-credit model that tracks the basketing rules across the remaining vest.

She reviews content on mobility, sourcing rules, and the equity-comp implications of expatriation.