Security and compliance

Taxpayer consent under IRC section 7216

Section 7216 and its regulations restrict how a tax return preparer discloses return information. Before any return information is disclosed to a preparer outside the United States, your firm needs the taxpayer's written consent, obtained before the disclosure, because retroactive consent is not allowed. Consent to use information and consent to disclose it are separate documents, and a consent that states no period lasts one year from signature. For Form 1040 filers, Revenue Procedure 2013-14 sets the format and the mandatory statements.

What we do: we do not begin work on a return until your firm confirms the consent is on file, and we give you a consent checklist. Read the section 7216 guide.

Social Security numbers

The regulations do not allow a preparer to obtain consent to disclose a taxpayer's Social Security number to a preparer outside the United States unless the information is protected by an adequate data protection safeguard and the consent request says so. Where that condition is not met, numbers are masked before work is shared.

A written information security plan

The FTC Safeguards Rule requires tax and accounting firms to keep a written information security plan, and the IRS publishes a template in Publication 5708. Our plan follows that structure: a responsible individual, a written risk assessment, access controls and encryption, staff training, oversight of service providers, an incident response plan and regular review. It is available to your firm to review before any engagement starts. Read the WISP guide.

How access works

• Work happens in your firm's systems or a secured workspace, never on personal devices
• Multi factor authentication on every system that holds client data
• Access granted per person and per client, and removed the day it is no longer needed
• No downloads to local machines, no email attachments and no removable media
• Confidentiality agreements signed by everyone who works on your files

PTINs for every preparer

Anyone who prepares, or assists in preparing, federal tax returns for compensation needs a Preparer Tax Identification Number. Preparers outside the United States apply using Form W-12 with Form 8946. Everyone who prepares returns for us holds one.

This page describes how the work is organised. It is general information, not legal advice. Your firm decides what its own obligations require.