Professional Tax Partnerships

Most expat tax situations are straightforward enough for a generalist. Some aren’t. We act as the technical back-office for CPAs, tax attorneys, financial advisors, and accounting firms when a client’s situation requires cross-border expertise that exceeds standard in-house capabilities, from PFIC computation to Kovel-protected analysis to Canadian cross-border filings.
Every engagement is scoped individually. All work product is prepared to your specifications and ready to incorporate into your client’s return.
Important: GILTI has been renamed and restructured for 2026.

The One Big Beautiful Bill Act (signed July 4, 2025) replaced GILTI with a new regime called Net CFC Tested Income (NCTI), effective for tax years beginning after December 31, 2025. The tangible asset exclusion (QBAI) has been eliminated, the deduction rate has changed, and planning strategies from prior years may no longer apply. Any references to GILTI on this page reflect the pre-2026 regime,  we are fully current on NCTI and its implications for your clients. 

Contact us to discuss how these changes affect an active engagement.

What We Do for Professional Partners

Not sure which service applies to your client’s situation? Here’s how we typically work with firms.
Contact us to discuss how these changes affect an active engagement.

Your client has foreign mutual funds or passive foreign investments.

PFIC reporting under Form 8621 is one of the most technically demanding areas of expat tax, and one that large commercial tax software platforms can struggle to handle correctly. The multi-level computation required for the various PFIC methods (default, QEF, mark-to-market) is something most generalist preparers encounter rarely, if at all.
We prepare Form 8621 with all required statements, ready to incorporate into your client’s 1040. We handle all PFIC calculation methods and provide fully documented work product.
$200
Details
  • $200 per form with completed Excel file
  • $200/hr without

 

Your client owns a foreign corporation.

Form 5471 has quadrupled in length since 2016. It now encompasses CFC tested income (formerly GILTI, now renamed NCTI under the OBBBA), the Section 965 transition tax, and the existing Subpart F regime. The IRS estimates approximately 200 hours to comply per shareholder, and penalties for non-filing or substantial non-completion start at $10,000 per form per year.
We prepare Form 5471 for all categories of filers, including complex multi-entity structures requiring Section 962 elections and high-tax exception analysis. Available alongside a return we are preparing or as a standalone engagement.
Starts at $500/hr

Your firm needs tax expert support under attorney-client privilege.

We are experienced in working with law firms under Kovel agreements, arrangements that extend attorney-client privilege to a tax expert’s communications when the work is performed under the direction of an attorney. Our Enrolled Agents and U.S. Tax Court Practitioners are qualified to serve in this role for matters involving IRS audits, penalty abatement, tax litigation support, and complex compliance situations.

Priced hourly

Your client has Canadian filing obligations your firm doesn't handle.

U.S. accounting firms regularly encounter clients with Canadian T1 returns, T1135 foreign property reporting, TFSA and RESP foreign trust reporting, and CRA correspondence obligations. We can prepare the Canadian return or specific Canadian forms as a complement to your engagement.
Starts at $270

Your client has CFC income or needs international tax planning support.

The GILTI regime was replaced by Net CFC Tested Income (NCTI) for tax years beginning after December 31, 2025. The tangible asset exclusion has been eliminated, rates have shifted, and clients who previously relied on QBAI to offset CFC income inclusions may face materially different results. We provide NCTI computation, Section 965 analysis, Section 962 election modeling, high-tax exception analysis, and entity classification support.
Priced hourly

Additional Services Available to Professional Partners

Some situations require additional forms beyond what’s covered above.
Common requests include:
Form 8865

Foreign partnership reporting

Starts at $550 /hr alongside a return
$660 /hr standalone
Form 5472

Foreign-owned U.S. entity reporting

Starts at $550 /hr alongside a return
$660 /hr standalone

Historic cost basis calculations

$450 /hr
Form 3115

Change of accounting method

$450 /hr
Form 1120 series

U.S. corporations

Starts at $1500
Form 1065

U.S. partnerships

Starts at $1500
Form 1041

Trusts and estates

Starts at $1000
Forms 706/706NA

Estate tax

Starts at $975
Form 709

Gift tax

Starts at $550

Engagements signed within four weeks of a filing deadline are subject to additional fees.

Who We Are

Our team includes Enrolled Agents (EA), Certified Public Accountants (CPA), Juris Doctors (JD), and U.S. Tax Court Practitioners (USTCP). The USTCP designation is one of the most specialized in U.S. tax practice, held by fewer than 300 practitioners nationwide. AET has been exclusively focused on U.S. and cross-border expat tax for over 30 years.

We work with firms of all sizes — from solo practitioners who occasionally encounter an expat situation to larger firms with ongoing cross-border needs. Our team is available for direct collaboration with your client or exclusively through your firm, depending on what the engagement requires.

Frequently asked questions

Most begin with a brief conversation about your client’s situation and what you need from us. We scope the work, agree on deliverables and fees, and begin once the engagement is confirmed. For standalone form preparation — Form 8621 or Form 5471 — we deliver fully documented work product ready to incorporate into your client’s return.

Yes. We are experienced in working under Kovel agreements with law firms where attorney-client privilege needs to extend to tax expert communications. Contact us to discuss the specific arrangement.

Either. We can work directly with your client under your supervision, or liaise exclusively through your firm. We follow whatever arrangement best serves the engagement.

What credentials do your specialists hold? Our team includes Enrolled Agents, Certified Public Accountants, Juris Doctors, and U.S. Tax Court Practitioners. Many of our specialists have decades of experience in complex expat and cross-border tax matters.

Turnaround depends on complexity and current capacity. We recommend engaging well in advance of filing deadlines — our specialist team operates on a waitlist basis during peak season.

Yes. Complex multi-tier entity structures, multiple intra-company transactions, and cross-border corporate structures are a core part of what our team handles. First-year engagements for complex forms like Form 5471 require additional scoping time.

Get In Touch

Professional partnership inquiries are handled separately from individual client engagements. Please complete the form below and a member of our team will be in touch within two business days.

Prefer email? Contact us at [email protected] with “Professional Tax Partnership” in the subject line.

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