How is the fee actually set?
On the first call we establish the scope — countries, years, entities, filings — and quote a fixed fee for it in writing. If the scope changes we re-quote before continuing, and nothing is filed until you have approved it.
Can you work with my existing accountant?
That is how most of these engagements run. They keep the domestic file, we take the cross-border piece, and the boundary is agreed in writing so nothing is done twice or missed.
What should I have ready before I call about a cross-border file?
A few things make the first conversation useful. Which countries you have been resident in, and roughly when each period started and ended. Which countries the income comes from, and what kind of income it is. Which years, in each country, are already filed and which are not. And any letter you have received from a tax authority, because the date on it usually decides the order of the work. You do not need the documents themselves at that stage. You need to be able to describe the shape of the position accurately, because that is what the scope and the fixed fee are built from. Call +1 (416) 619-0068.
Can you give me a price before I send my documents?
Yes, once the scope is clear. The fee is set by what the work contains — how many years, how many countries, whether a return has to be rebuilt rather than prepared — not by the hours it takes. So the first conversation is mostly about establishing those boundaries. The fee is then agreed in writing before any work starts and it does not move. If something turns up that sits outside the agreed scope, a missing year, a second country, an entity nobody mentioned, the work stops and the extra is quoted in writing before it goes ahead. You are never told the number afterwards.
What actually happens after I first get in touch?
The first conversation is diagnostic. We are trying to work out which rules govern your position, because that decides everything downstream — which returns are required, in which order, and what has to be settled before anything can be prepared. Residence usually has to be established first. Then the outstanding years are listed, country by country. Then the scope is written down and priced. Only after you have agreed that in writing does document collection begin. Files that go wrong almost always went wrong here, by starting the return before the question of which rules apply was answered.
Who will I be dealing with once the work starts?
One named adviser is answerable for the file, and that person is the one who scoped it. Preparation may be done by someone else, and a return is read by a reviewer before it is signed, but the person who agreed the scope with you does not hand the file on and disappear. This matters more on cross-border work than on a single-country return, because the decisions taken at scoping — residence, which country taxes first, which years go in and in what order — are carried through the whole engagement and have to be defended by whoever made them.
Is it safe to tell you about years I never filed?
Tell us. It is covered by the confidence you would expect of any adviser, and more practically, a scope built on a partial account is a scope that will have to be redone. Unfiled years, an account in a country you have not mentioned, a company you own a share of — each of those changes which rules apply, not merely how long the work takes. People understate the position at first contact because they are bracing for a lecture. You will not get one. What you will get is an accurate view of what has to be filed and what it will cost.
I have a letter with a deadline on it — what now?
Say so at the start of the conversation, and read out the date and what the letter asks for. A demand to file, a request for documents and a proposal to assess are three different things, and they set different orders of work. Where a date is running, the sequence changes: the immediate response is prepared first and the wider catch-up is scoped around it, rather than the other way round. Bring the letter to the conversation rather than describing it from memory, because the wording of what is being asked for is usually what determines the answer.
What is a double tax treaty and what does it actually do?
It is an agreement between two countries that divides up the right to tax. Article by article it decides which country taxes employment income, dividends, interest, royalties, pensions, property and business profits — and where both may tax, it caps what the source country can withhold and tells the other to give credit. It also breaks residence ties and opens a government-to-government channel for disputes. What it never does is apply itself: a treaty position is claimed. See our treaty work.
Branch or subsidiary — which should we use to expand?
A branch keeps one taxpayer: results consolidate at home, losses are usable sooner, and the exposure is that the branch is a permanent establishment whose profit the host country taxes, sometimes with a branch tax on repatriation. A subsidiary is a separate taxpayer with limited liability and local rates, at the cost of withholding on dividends home and transfer pricing on everything between them. The deciding facts are usually expected losses, liability and exit plans. See branch against subsidiary.