Final check before signing — PTIN holder vs EA in Paris for SFOP, would appreciate a sanity check
Hi everyone,
I'm about to engage a tax professional in Paris for my Streamlined Foreign Offshore Procedure, and I'd love a final sanity check from this community before signing the engagement letter. I've done quite a bit of due diligence already, but a last external perspective would be welcome.
**My situation:**
- French-American dual citizen, lived in France my whole life
- Modest income (< €50k/year), salaried
- French bank accounts (Livret A, etc.) + one PEA with a few ETFs (so potential PFIC reporting)
- Clear non-willful case (never knew about US tax obligations)
**The three professionals I evaluated:**
**Option 1 — Expat Assist Paris (Aaron Scott)**
- Fee: ~€3,750 for the full SFOP package (3y 1040 + 6y FBAR + Form 14653)
- Free 30-min initial consultation
- During the call, spontaneously raised PFIC and the France-US tax treaty as key topics for my case
- **Verified status: PTIN holder.** He was previously an Enrolled Agent but the EA credential expired on March 31, 2022. This was confirmed both by the IRS Office of Enrollment (epp@irs.gov) following my direct inquiry, and by Aaron himself when I asked. His explanation was that *"this decision was made voluntarily. I have transitioned to practicing solely as a PTIN holder, as the EA designation was no longer necessary for the scope of tax preparation services I provide. I continue to offer professional tax preparation for my clients under my current PTIN registration."* He was straightforward about it when asked directly.
- 37 five-star Google reviews
**Option 2 — Smith Carmichael (Greg Smith)**
- Fee: €5,000–7,000 for the same scope
- €480/hour initial consultation
- During the consultation, did NOT mention PFIC or the France-US tax treaty — even though both are central to my case
- Verified status: EA active (confirmed in IRS FOIA listing)
- 30+ years of experience, ex-IRS field agent
**Option 3 — Kaylee Blackston (Horton Tax → going independent)**
- Fee: €4,500–6,500 HT for SFOP, €1,600 HT minimum annual fee afterward
- Verified status: EA active
- Currently transitioning from Horton Tax to her own practice (timing uncertain)
**My current thinking:**
I'm leaning toward Option 1 (Aaron Scott) for these reasons:
- He demonstrated the best technical relevance for my specific case (PFIC + treaty mentioned upfront)
- 30–50% cheaper than the EA-credentialed options
- I value technical competence over credential status (the SFOP is unilateral, so EA representation rights matter less)
**My concern:**
- He's a PTIN holder, not EA — no representation rights beyond what he files
**My question to the community:**
Am I missing something obvious? Has anyone here gone with a PTIN holder over an EA for SFOP and regretted it (or not)? Would you prioritize differently in my shoes?
Genuinely grateful for any input before I sign.
Thanks!