Milliseconds or frames
Milliseconds are absolute and portable, which makes them right when you are matching a known device latency — Bluetooth headphones and wireless speakers often sit in the 100–200 ms range. Frames are relative to the video, which makes them right when you are working from an editor’s report or matching another clip in a 30 or 60 fps project. At 30 fps one frame is about 33 ms, and at 60 fps about 17 ms, so a “two frames late” note translates cleanly either way.