Section 7216 Consent & WISP Kit for CPA Firms Using Offshore Staff

If your firm sends tax return information to preparers outside the United States, two sets of rules apply. The first is Internal Revenue Code §7216 and Treas. Reg. §301.7216-3. They require the taxpayer's written consent before you disclose return information to a preparer located abroad. The consent must be a separate document, signed and dated before the disclosure, and it must follow the wording set out in Rev. Proc. 2013-14, including the name of the country where the information will go.

The second is the FTC Safeguards Rule. Tax preparers count as financial institutions under 16 CFR Part 314, so your firm needs a Written Information Security Plan (WISP) that covers every service provider with access to client data. IRS Publication 4557 gives practical controls that most firms use as their baseline.

This kit gives you the documents to meet both rules without starting from a blank page. Your firm remains responsible for obtaining client consent and should have its own counsel review the templates.

What's inside

• Taxpayer consent template in the Rev. Proc. 2013-14 format for disclosure to a preparer outside the US
• Consent tracker so no return is released before consent is on file
• Engagement-letter wording that explains offshore preparation to clients
• WISP service-provider addendum for the FTC Safeguards Rule (16 CFR Part 314)
• IRS Publication 4557 controls checklist to review any offshore provider

Want the full picture first? Read §7216 explained or see how we prepare US tax returns for CPA firms.