Frequently asked

    Honest answers to the questions clients ask before they engage.

    We are not in the business of marketing copy. The answers below are the same ones we give in a discovery call. If a question is missing, that is usually a sign it deserves a real conversation.

    01

    How we work

    Internationally active entrepreneurs and operators. Globally mobile families. Closely-held businesses with cross-border revenue, contractors, or holding structures. We are not a fit for high-volume retail compliance, anonymous shell formation, or single-touch tax filing.

    We accept clients we believe we can serve well across multiple years. The intake process is designed to confirm fit before we propose a scope.

    Consultations are billed by the hour, at rates that vary by the seniority of the advisor on the call. Contact us for current rates before you book.

    Engagements that follow are billed transparently on a per-item basis. Each deliverable carries a fixed, written price, with scope and timing agreed before work begins. You see exactly what you are paying for, item by item, with no open-ended hours and no surprises.

    No. We work with clients from across the world, including Europe and Australasia. The constant is the corridor, not the passport.

    Our advisory scope is strictly Panama-anchored. We advise on movement to and structuring through Panama, and on the U.S. and Canadian sides of that corridor. We do not advise on local taxation inside European or Australasian jurisdictions; for those questions we coordinate with vetted local counsel. We can, and do, help clients relocate to Panama from those jurisdictions.

    A short discovery call to understand the situation. If we believe there is fit, we issue a written engagement letter that sets out scope, deliverables, timeline, and fee. KYC and information security run in parallel. Strategy work begins only after engagement is signed.

    We do not give jurisdiction-specific recommendations on a discovery call. That is the work itself, not a sample.

    02

    Confidentiality

    Strict KYC at intake is a feature, not a friction. We collect what we need, encrypt it in transit and at rest, and limit internal access on a need-to-know basis. Clients who are not willing to be properly identified are not clients we engage. The discipline is what makes the work possible across regulated jurisdictions.

    No. Rothbard Group S.A. is a boutique cross-border tax and corporate advisory firm. Our work sits within tax and corporate advisory. When client matters require legal opinions, litigation, or local registration filings, we coordinate with vetted local counsel in the relevant jurisdiction.

    03

    Jurisdictions

    Three operating jurisdictions: the United States, Panama, and Canada. That is the scope we can defend year after year, in writing. We do not chase trendy passport schemes or fringe jurisdictions, and we do not take on work outside the corridor where we have direct, durable expertise.

    No. Panama's Friendly Nations Visa was redesigned in 2021 and has since lost most of the practical advantages that made it attractive for our clients. The route most people imagine when they ask for Friendly Nations no longer exists.

    We now route relocation work through the Qualified Investor visa, the Pensionado, and the Remote Workers visa, depending on profile. The article 'Why we don't sell Friendly Nations anymore' explains the reasoning.

    Yes, and we will be honest about what that costs. Section 128.1 of the Income Tax Act treats most departing residents as having sold most of their property at fair market value on departure. The exit tax is the single most underestimated cost in Canadian relocation planning. We model it, structure around what we can, and tell you what is unavoidable. Anyone selling clean Canadian exits without modeling the deemed disposition is not advising you, they are selling to you.

    04

    Panama tax

    No. Panama taxes only Panama-source income. Income earned outside Panama is foreign-source and outside Panamanian tax, for individuals and companies alike. It is however important to note that entities may exceptionally face a 15% tax on foreign passive income within the scope of the new 2026 economic substance law. The catch is that "foreign-source" means transactions that are consummated and take effect outside Panama, not simply money received from abroad, and your home country may still tax you.

    No. Permanent residency is an immigration status from the Servicio Nacional de Migracion. Tax residency is a separate test (more than 183 days, or a genuine center of vital interests) confirmed by a tax residency certificate from the DGI. Holding a residency card does not, by itself, end your home-country taxes.

    05

    U.S. tax

    An Enrolled Agent is a federally licensed tax practitioner authorized by the U.S. Department of the Treasury to advise on U.S. tax matters and represent clients before the Internal Revenue Service at every level, without restriction. The credential is granted only after passing a three-part Special Enrollment Examination and is renewed through ongoing education. It is the highest credential the IRS bestows on a tax practitioner. Our practice is led by a licensed Enrolled Agent.

    It depends on whether you have effectively connected income, a U.S. permanent establishment, U.S. source income, or income that triggers withholding under FDAP rules. None of those questions answer themselves from a website. The right answer in our work has been, repeatedly, that founders pay either too much because no one explained territorial sourcing, or too little because no one ran the analysis. We run the analysis and document it.

    NCTI (net CFC tested income) replaced GILTI for tax years beginning after December 31, 2025. It is not just a rate change: the base is broader (the tangible-asset deduction is repealed), the section 250 deduction is smaller, and the foreign tax credit is more generous. It applies to US shareholders of controlled foreign corporations.

    Form 5472 is an informational return used to report related party transactions; that form is required when US LLCs are foreign-owned, including single-member LLCs that are disregarded entities. The $25,000-per-year penalty for a missed filing is real, and even funding your own LLC can count as a reportable related party transaction.

    For non-resident alien entrepreneurs, US tax depends on effectively connected income (ECI), not on having US customers. The test is where your business activity actually happens (your people, office, presence, where inventory is sold), not where your clients are. Even at zero tax, you usually still have a US filing obligation.

    06

    Canadian tax

    Canada applies a deemed disposition under section 128.1: on the day you cease to be a tax resident, the CRA treats you as having sold most of your property at fair market value and taxes the resulting gain, even with no actual sale. Some assets are excluded, and the tax can sometimes be deferred.

    Often, but not always. Canada withholds a flat 25% on RRSP withdrawals by non-residents, and with no Canada-Panama treaty there is no reduced rate. A Section 217 election lets you file a Canadian return and be taxed at graduated rates instead, which can recover part of the 25% in a low-income year.

    07

    Structure

    Often, neither in isolation. The right entity is the one that fits the operating model, the owner's residency, the tax posture across borders, and the eventual exit. We have published an article, 'Florida vs. Wyoming, not the choice you think it is,' that walks through the substantive trade-offs. The framing of the question itself is usually wrong.

    No. Anonymity-driven structuring is incompatible with how the U.S., Canada, the EU, and Panama now share information. The structures we build are private but not invisible, compliant but not over-disclosed. If a client's first requirement is opacity, we are not the right firm.

    Still on your mind

    The best answer is usually a conversation, not a paragraph.

    Read articles

    In closing

    Let’s talk.

    A single conversation usually clarifies more than a month of research. We engage on a value basis, and every introduction begins with a direct, confidential exchange.

    Return to top

    We advise on

    Rothbard Group S.A.

    A boutique cross-border tax and corporate advisory firm. Licensed U.S. Enrolled Agent authorized to practice before the Internal Revenue Service.