Competitively priced PE / structure opinion — fixed-fee price

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Quoted in writing before the work starts. Reviewed with you before it is filed. From $999, quoted before work starts. Agreed in writing before the work starts. Competitively priced PE / structure opinion with a fixed fee agreed in writing before any work starts. Call the 24-hour helpline on +1 (416) 619-0068, or request a written quote today.

+1 (416) 619-0068 See fixed fees
  • 15+Years of cross-border experience
  • 18,000+Clients served
  • 5.0Google rating
  • 4Global offices — India, USA, Canada & UAE
  • 15+ years of cross-border experience
  • 24-hour helpline: +1 (416) 619-0068
  • 18,000+ clients served
The promise

PE / structure opinion is quoted as a fixed fee before any work begins, from $999 for a standard engagement. You review the finished work before it is filed, and if the scope changes we re-quote before continuing.

What the engagement actually covers

A written opinion on whether the activity creates a taxable presence, what would be attributable to it if it did, and what could be changed to alter the answer.

The team at work in the open-plan office

Three tiers

TierFixed feeWhat it covers
Standardfrom $999The straightforward case: one year, one country pair, records in order. Corporate cross-border filing at the published rate.
Complexfrom $999An information return, a certificate application or a second jurisdiction in the same engagement.
Multi-year or projectquoted on scopeMultiple years, a disclosure route or an entity structure. Priced per year and per entity and quoted before any work begins.

These are the fees on our own published schedule. The exact number for your engagement is confirmed in writing after the first call, and it is the number on the invoice.

What moves you up a tier

On this job specifically: How many people and places are involved. One employee working from home is one analysis; a sales team, a warehouse and a contractor with signing authority is several.

  • How complete the documents are when they arrive — a reconstructed year costs more than a documented one
  • The number of tax years in scope, because a catch-up package is priced per year
  • Whether a foreign authority has to issue something before we can file
  • Whether an information return or a certificate application travels with the filing

What adds cost

Two things, mostly: reconstruction and waiting. Reconstruction is rebuilding a year from bank statements because the records are gone; waiting is a certificate or a slip that has to come from a tax authority or a foreign institution before we can file. We tell you which of the two is in play at the quote stage rather than at the invoice stage.

The assumption we correct most often

That an employer-of-record contract answers the question. It handles the payroll; the presence question is about what your people actually do.

What is never charged

  • Answering a question about the scope we already quoted
  • Re-sending a copy of a filing we prepared for you
  • The first call to the 24-hour helpline, where the scope is set

Get the quote

Bring the last two years of returns from each country involved, the slips or certificates for the income in question, and the dates — arrival, departure, or the transaction date. That is enough for us to tell you what has to be filed and what it will cost. Send us the facts and we will tell you what has to be filed and what it costs.

Request a fixed-fee quote

Reviewed against current guidance for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.

Where corporate tax services comes into this file

People reach this page searching for corporate tax services. It is covered here as it applies to PE / structure opinion — who it applies to, what has to be filed, and what it costs, at a fixed fee agreed before the work starts.

From first contact to filed return

  1. Send the documents as they are

    No tidying required — forward what you have and we tell you what is missing.

  2. Get a fixed quote in writing

    Priced from your actual documents before any work begins, not estimated after.

  3. Both countries prepared together

    One team builds the filings against each other so the relief lands exactly once.

  4. Review, then file

    You approve the finished work before we file it.

What you are actually buying with PE / structure opinion price

Factor Legal Quotient Hourly billing model
Pricing A fixed fee, agreed in writing before work starts Hourly, billed as incurred
Experience 15+ years of cross-border work, 18,000+ clients Varies by file
Both sides of the border Prepared together by one team, so relief is claimed exactly once One country at a time, reconciled later
Who reviews it A named practitioner, published on the page Whoever the queue reaches
Where the work happens Our offices in India, the USA, Canada and the UAE Whichever single office you can travel to

Key terms behind this page, defined

US estate tax
A tax on the value of US-situs assets at death, reaching non-residents who never lived in the United States, with a much smaller exemption than a US person receives.
Published fee
A fee listed on this site for a defined scope, so the number is known before the first call. Legal Quotient Consultants publishes every fee it charges and confirms the one for your engagement in writing before any work starts.
Repatriable funds
Money that may lawfully be sent out of India, determined by the account it sits in and how it got there — a separate question from whether tax is owed.
QEF election
An election to treat a foreign pooled investment as a qualified electing fund, taxing its income currently instead of under the default throwback regime.

PE / structure opinion price — what the published fees look like

All three are published fee pages, each with its scope stated. Your documents set the quote before work begins, and the quote is the invoice.

Transfer pricing documentation

$2,500fixed, before work starts

Covers: Documentation for transactions between related companies: the method, the comparables and the file an authority asks to see.

See this fee page

Corporate cross-border filing

$999fixed, before work starts

Covers: The corporate return and its cross-border schedules as one engagement, so the group files a consistent position everywhere.

See this fee page

Payroll & mobility setup

$999fixed, before work starts

Covers: Registrations, withholding and the employer obligations that follow staff working across a border, set up once and correctly.

See this fee page

The difference a dedicated cross-border team makes

The reporting penalties get named early

The heaviest exposure on a cross-border file is usually a disclosure form, not the tax. We identify which ones apply before a deadline turns into a penalty.

4 global offices

Meet us in person in India, the USA, Canada and the UAE, or send everything through the secure portal — the same process either way.

Both sides prepared together

Two returns built against each other by one team, so relief is claimed exactly once and nothing falls between the two systems.

Every figure on a page is traceable

Where a rate or a threshold appears in our writing it names the tax year it belongs to. Where it could not be confirmed, the page describes the mechanism and quotes no number.

The firm’s founder at his desk in the Delhi office

How the engagement runs, phase by phase

Step 1

First conversation

We establish what happened and when, because every position here is anchored to a date

Step 2

Written quote

A written scope and a fixed price, so you know the cost before committing

Step 3

Preparation and sign-off

The filings are prepared, cross-checked against each other, and reviewed by name

Step 4

Submission

You see the result, approve it, and we file it

Two of the firm’s advisers at the glass desk in the Delhi office

A fixed quote first, in writing

  • Step 1: Hand over the paperwork in any state – Sorting it is our job. Send what exists and we identify what is missing from it.
  • Step 2: Priced before a single form is opened – The fee comes from the documents, agreed in writing, and stays where it was agreed.
  • Step 3: One position across every return – The same facts, filed consistently on each side, so nothing contradicts anything else.
  • Step 4: Filed after you have read it – The completed work reaches you before it reaches an authority.

Quoted up front, in writing.

Contact Us 24-hour helpline +1 (416) 619-0068

Keep reading, sideways

Browse sideways: the pages below answer the neighbouring questions.

Core services for this situation

Social security & totalization certificates Social security & totalization certificates — the guide, the FAQ and the fixed fee.
First-year proration schedule — Canada The full guide to first year proration schedule Canada, with the fee fixed before any work starts.
Foreign company with an Indian subsidiary — filings Its own page: foreign company with an Indian subsidiary — filings — mechanism, deadlines and published fees.
Selling into the US without a US entity Everything on selling into the US without a US entity, at the same depth as this page.
Leaving India — becoming an NRI Leaving India — becoming an NRI — the guide, the FAQ and the fixed fee.
Artistes and sportspersons — the treaty article The full guide to artistes sportspersons treaty article, with the fee fixed before any work starts.
Form 3CD — tax audit report (India) Its own page: form 3cd India — mechanism, deadlines and published fees.
Form 8858 — foreign disregarded entity Everything on form 8858 foreign disregarded entity, at the same depth as this page.
Tax risk register for cross-border groups Tax risk register for cross-border groups — the guide, the FAQ and the fixed fee.

Who we bring this work to

Tax for travel nurses (us contracts) Travel nurses (US contracts) tax — the guide, the FAQ and the fixed fee.
Tax for airline pilots The full guide to airline pilots tax, with the fee fixed before any work starts.
Food & beverage brands cross-border tax Its own page: food & beverage brands cross border tax — mechanism, deadlines and published fees.
Technology & SaaS — what we charge Everything on technology & saas what we charge, at the same depth as this page.
Airline pilots — your filing calendar Airline pilots your filing calendar — the guide, the FAQ and the fixed fee.
Airline pilots — what we charge The full guide to airline pilots what we charge, with the fee fixed before any work starts.
Management consultants — relief you're probably missing Its own page: management consultants relief you're probably missing — mechanism, deadlines and published fees.
Franchise owners — what we charge Everything on franchise owners what we charge, at the same depth as this page.
Construction & contracting — what you owe in each country Construction & contracting what you owe in each country — the guide, the FAQ and the fixed fee.

The corridors we work every week

Canada–Netherlands tax corridor Canada Netherlands tax — the guide, the FAQ and the fixed fee.
Georgia tax for expats — country guide The full guide to georgia tax for expats, with the fee fixed before any work starts.
Belgium tax for expats — country guide Its own page: Belgium tax for expats — mechanism, deadlines and published fees.
US–UAE tax corridor Everything on US UAE tax, at the same depth as this page.
Bahrain tax for expats — country guide Bahrain tax for expats — the guide, the FAQ and the fixed fee.
Thailand tax for expats — country guide The full guide to Thailand tax for expats, with the fee fixed before any work starts.
Seychelles tax for expats — country guide Its own page: seychelles tax for expats — mechanism, deadlines and published fees.
Panama tax for expats — country guide Everything on panama tax for expats, at the same depth as this page.
Morocco tax for expats — country guide Morocco tax for expats — the guide, the FAQ and the fixed fee.

The people on your file

Five named practitioners, each with the part of a cross-border file they carry. Every page on this site says who reviewed it, and the reviewer is one of these people rather than an unnamed team.

Udit Gupta

Udit Gupta

Cross-Border Tax Expert

CA (ICAI), In-Depth Tax Trained

Reviews and signs off the practice's cross-border positions, and carries final responsibility for the treaty analysis on every file that leaves the office.

Abhinav Gupta

Abhinav Gupta

Canada Tax / International Tax

Canada Tax, International Tax, Cross-Border Tax, Transfer Pricing

Canadian returns with foreign income, non-resident filings, and the transfer-pricing documentation that runs alongside intercompany work.

Raghav Gupta

Raghav Gupta

International Tax

International Tax, Transfer Pricing Specialist

Benchmarking, method selection and the local-file and master-file sets that support a group's pricing policy under examination.

Anmol Mittal

Anmol Mittal

Canada and US tax

CPA Canada, CPA USA, CA (ICAI)

Files that have to be right on both sides of the border at once — dual filings, streamlined catch-ups, and the foreign tax credit reconciliation between them.

Vinayak Indolia

Vinayak Indolia

CFO advisory

CPA, CA. Fractional CFO and Senior Advisory Specialist

Groups that need the tax position and the finance function to agree: structure reviews, intercompany policy, and the reporting a board can act on.

Meet the whole team

What these engagements turn on

Case study 1

Three Countries in One File and Two Treaties That Disagree

Income sourced in one country, paid to a resident of a second, held through an entity in a third: three bilateral treaties, no three-way rule. The analysis works out which pair governs each flow, and whether the middle entity is entitled to anything at all.

Read how this one runs
Case study 2

One Salesperson Abroad, and a Corporate Filing Obligation

A single employee with authority to conclude contracts can create a taxable presence for the whole company. The review tests what the person actually does against the treaty article, and where a presence exists, works out what profit is attributable to it.

Read how this one runs
Case study 3

An Indian Company Paying a Foreign Supplier

Payments abroad carry deduction at source and a certification filed before the money moves. Whether the treaty reduces the rate depends on what is being bought, and the classification is the decision the whole filing rests on.

Read how this one runs
Case study 4

Indian Transfer Pricing Certification With a Hard Deadline

An Indian entity with international related-party transactions needs an accountant's report filed by a date of its own, ahead of the return. The work is reconciling the transactions to the books first, because the report is only as defensible as that reconciliation.

Read how this one runs
Case study 5

A Shareholder Loan Across a Border at No Interest

An interest-free loan between related companies is priced as if it carried interest, and in some cases a deemed benefit follows as well. The file sets a rate against the borrower's own credit profile and documents the terms that support it.

Read how this one runs
Case study 6

A US LLC Owned From Canada

The two countries classify the vehicle differently, so relief that ought to apply frequently does not and the same profit can be taxed in both hands. The engagement examines whether the structure can be changed and what the change itself costs.

Read how this one runs
Case study 7

Moving Money Out of India and the Certificates It Needs

A remittance out of India needs its tax position certified before the bank will process it. The file establishes the character of the funds, produces the certification, and keeps the position consistent with the returns already filed.

Read how this one runs
Case study 8

An Executor Administering Across Two Systems

An executor can be personally liable for what is assessed after a distribution, and the clearance that protects them is obtained rather than assumed. The engagement sequences the filings so the distribution is safe when it happens.

Read how this one runs

All case studies — every published engagement in one place.

Delivery, coverage and how we work

Each of these carries its own guide, pricing pointers and FAQ.

Where the work is delivered

More coverage detail

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

Strategy and compliance for income, assets and families spread across borders.

Treaty residency & tie-breaker
FATCA reporting (Form 8938)
Foreign tax credit (Form 1116)
Multi-country filing calendar
Real estate holding structures
International tax planning
Pre-immigration tax planning
Family office structures
One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.

U.S. & Cross-Border Tax Returns

Form 1040 from abroad
US state non-resident returns
FBAR (FinCEN 114) filing
Form 5472 — foreign-owned US corp
FIRPTA withholding (Form 8288)
US estate tax exposure
IRS streamlined foreign offshore
PFIC reporting (Form 8621)
Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.

Expat & Emigration Tax

Departure tax leaving Canada
T1161 properties on emigration
Residency planning
Step-up in cost base on arrival
Split-year residency
Employment income under a treaty
Social security totalization
Returning to Canada after years abroad
The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.

Non-Resident Canadian Tax

Section 216 rental return
NR4 & NR6 withholding
Section 217 pension return
Section 116 clearance certificate
Regulation 105 waiver
Non-resident employment income
Taxable Canadian property
Part XIII withholding review
Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

s.247 contemporaneous documentation
Functional & risk analysis
Benchmarking study
Intercompany agreements
Country-by-country report
BEPS & Pillar Two
Permanent establishment risk
TP audit defence file
Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.

Cross-Border Estates & Trusts

Cross-border wills
US estate tax for non-resident aliens
Terminal return & clearance certificate
Non-resident trusts (s.94)
T1141 & T1142 trust reporting
Inheriting property abroad
Graduated rate estates
Post-mortem planning & pipeline
Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

Entity selection across borders
Business profits & PE
Intercompany loans & thin cap
Paying dividends to a foreign parent
Global mobility & day tracking
Debt vs equity funding
Branch or subsidiary
Cross-border M&A due diligence
Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.

India Tax for NRIs & Returning Residents

NRI residency day tests
NRE, NRO & FCNR accounts
TDS on property (s.195)
Lower or nil TDS certificate
Repatriating sale proceeds
Capital gains on Indian shares
India–Canada DTAA
ITR-2 for NRIs
The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.

Canadian Tax with a Foreign Element

T1135 foreign property
T1134 foreign affiliates
Departure tax
Newcomer's first return
Returning to Canada
Split-year residency
US citizens in Canada
Canada–US corridor
Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.

UAE Tax for Expats & Their Home Country

Expat tax in the UAE
Moving to the UAE
Moving back from the UAE
UAE property purchases
Retiring in the UAE
Canada–UAE corridor
India–UAE DTAA
US–UAE corridor
A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

Industries & Client Types We Serve Worldwide

Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies

Global E-commerce & Marketplaces

  • Foreign VAT / GST / sales tax registrations
  • Marketplace withholding reviews
  • Inventory nexus & PE analysis
  • Multi-currency books reconciled
Explore E-commerce & Marketplaces

Technology & SaaS

  • Cross-border revenue sourcing & withholding
  • IP structuring with real substance
  • Equity for cross-border teams
  • U.S. expansion: entity & PE setup
Explore Technology & SaaS

Cross-Border Real Estate

Foreign property income and sales are taxed in both countries by default; Section 216, FIRPTA and treaty credits are the standing toolkit.

Property is taxed where it sits, which is the one rule no treaty overrides. What the treaty does decide is the credit, the rate on the rent and what happens on the sale — and the clearance certificate on a disposition is applied for before closing, not after the buyer has already held the money back.

  • Section 216 rental returns
  • FIRPTA withholding recovery
  • Section 116 clearance
  • Treaty credit optimization
Explore Real Estate

Importers, Exporters & Manufacturers

  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
Explore Trade & Manufacturing

Athletes, Artists & Entertainers

  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
Explore Athletes & Entertainers

Remote Workers & Digital Nomads

  • Residency analysis before moving
  • Employer payroll exposure
  • Totalization & social security
  • Foreign tax credits
Explore Remote Workers

Investment Funds & Holding Companies

  • Treaty access & PPT reviews
  • FAPI & surplus computations
  • Withholding-efficient routing
  • Governance & substance
Explore Funds & Holdcos

PE / structure opinion pricing — questions we are asked

What is included in the fee for PE / structure opinion?

A written opinion on whether the activity creates a taxable presence, what would be attributable to it if it did, and what could be changed to alter the answer.

What would make PE / structure opinion cost more than the standard tier?

How many people and places are involved. One employee working from home is one analysis; a sales team, a warehouse and a contractor with signing authority is several.

Is the fee really fixed?

Yes, for the scope quoted. If the scope changes — another year appears, an entity turns up, a certificate becomes necessary — we re-quote before doing the work, so there is never an invoice you have not already agreed to.

Does a foreign-owned US entity need an EIN?

Yes, for almost anything it must do: file its returns, operate payroll, open a bank account, and act as a withholding agent on payments abroad. It is applied for on Form SS-4, and the part that stalls foreign owners is the responsible party — a real person with a US identification number is expected, and where none exists the application route and the supporting explanation both change. It is worth starting early because downstream registrations queue behind it. See EIN applications.

What is a permanent establishment?

The threshold at which a country may tax a foreign company's business profits. It is met by a fixed place of business — an office, a branch, a workshop — and also by a dependent agent habitually concluding contracts on your behalf, with separate rules for construction sites and, in some treaties, for services performed over a period. Cross it unnoticed and you owe returns and tax in a country you never registered in. See permanent establishment risk.

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.

Tax terms explained

Tie-breaker rulesFBARPaid-up capitalFaceless assessmentSubpart F incomeGILTIImporter of recordProtective returnSubstance-based income exclusionAdjusted cost baseAdvance pricing arrangementMLICloser connectionTDS Browse the full A–Z glossary

Related fixed fees and services

Related in this section

All pricingT106 information return — fixed-fee priceForm 3CEB certification (India) — fixed-fee priceAnnual compliance retainer — fixed-fee priceCross-border payroll setup — fixed-fee priceUS state nexus review — fixed-fee priceGST/HST non-resident registration — fixed-fee price

Also relevant

Local resident director services in CanadaManagement fee studyForeign-owned US company — filingsPaying royalties or licence fees abroad — withholdingCanadian company expanding to the US — LLCs and global taxesPaying from abroad — currency and method

Fixed fees

Form 3CEB certification (India) — fixed-fee priceUS state nexus review — fixed-fee priceEstate & trust returns — fixed-fee pricePE / structure opinion — fixed-fee price
No hourly billing, ever

A fixed fee for PE / structure opinion

Send us the facts. You will get a scope and a fixed fee in writing, and nothing starts until you agree to both.

Contact Us 24-hour helpline +1 (416) 619-0068 See fixed fees
  • 18,000+ clients served
  • Re-quoted, never silently invoiced
  • Rated 5.0 out of 5 stars on Google

Our practitioners are alumni of leading accounting and tax institutions

Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.

Request a Quote +1 (416) 619-0068