税务业务中的客户筛选、接受和终止的注意事项Client Screening, Acceptance, and Termination Considerations in Tax Engagements
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税务业务中的客户筛选、接受和终止的注意事项Client Screening, Acceptance, and Termination Considerations in Tax Engagements

Client Acceptance Procedures


While a checklist is the ideal method for client screening, some firms may use something less formal. Whatever the process, firms should determine the prospective client’s industry (or occupation, if an individual) and the necessary skills or competencies to complete the engagement. Firms should also be mindful of the ethical considerations regarding competency and refer to the AICPA Code of Professional Conduct section 1.300.010 (http://pub.aicpa.org/codeofconduct/Ethics.aspx) and U.S. Treasury Circular 230, “Regulations Governing Practice before the Internal Revenue Service,” section 10.51 (http://1.usa.gov/1LCri50). CPAs should inquire as to whether a client has current or former foreign bank accounts, which would trigger certain tax compliance matters not initially considered by many businesses and individuals. Finally, if the client was referred to the firm, the referral source should be reviewed. If the referral source is of high character, chances are the prospective client will possess the same. Firms should be skeptical of a client who has no referral source.

虽然核对表是筛选客户的理想方法,但有些公司可能会使用一些不太正式的方法。无论采用何种流程,公司都应确定潜在客户的行业(或职业,如果是个人)以及完成业务所需的技能或能力。公司还应注意有关能力的道德因素,并参考AICPA职业行为准则第1.300.010(http://pub.aicpa.org/codeofconduct/Ethics.aspx)以及《美国财政部第230号通知》,美国国内税务局(Internal Revenue Service)监管条例,第10.51(http://1.usa.gov/1LCri50).注册会计师应查询客户是否有经常或以前的外国银行帐户,这会引发某些税务合规事项,而这些事项初并没有被许多企业和个人考虑。后,如果客户是被转介给公司,则应审查转介来源。如果转介来源是高质量的,潜在客户也有可能拥有相同的信息。公司应该对没有推荐来源的客户持怀疑态度。

Background Checks


Despite the ease and speed with which it can be performed, an astonishing amount of firms fail to conduct even the simplest kind of background check. As with a client acceptance committee, the process can be quite formal, such as with the use of a third-party background check company, or it can be as simple as a review of public information available on the Internet. The results of a simple Google search can be revealing and could prevent the firm from engaging an undesirable client. In addition, the engagement team should discuss speaking to the prospective client’s prior tax preparer (consent is required), legal counsel, bankers, and other strategic professionals. Increased competition amongst background check companies has driven down the cost of such services, and firms should consider trying them.


税务业务中的客户筛选、接受和终止的注意事项Client Screening, Acceptance, and Termination Considerations in Tax Engagements

Code of Ethics and Circular 230 Issues


Reviewing the prior tax returns of a prospective client is quite common, and doing so may reveal errors in prior returns. Consequently, tax preparers should be familiar with the rules governing their responsibility once an error is found. Requests for records are governed by state-specific rules, which can be quite strict, as well as Circular 230. Successor preparers should be mindful of what records a prior preparer may or may not provide and the difficulties this may present.


Successor Tax Preparer Issues


While much guidance regarding communication with predecessor auditors exists (e.g., AICPA Statement on Auditing Standards 84 and AU section 315), very little exists regarding communication with predecessor tax preparers. Nevertheless, written authorization must be received prior to speaking to the former preparer. Once obtained, the successor should consider the following questions:


· ▪ Did the client accept and take the previous preparer’s advice regarding tax positions?

·  客户是否接受并采纳了先前填表人关于税务状况的建议?

· ▪ Were fees paid in a timely manner?

·  费用是否及时支付?

· ▪ Did the client suggest tax treatment without support?

·  客户是否建议在没有支持的情况下进行税务处理?

· ▪ What was the quality of their records?

· 他们的记录质量如何?

· ▪ Has the client switched preparers often?

· 客户是否经常更换填表人?


税务业务中的客户筛选、接受和终止的注意事项Client Screening, Acceptance, and Termination Considerations in Tax Engagements

Access to Records


While review of the previous preparer’s records may be limited by both regulatory guidance and firm policies (e.g., many firms will only permit access to records on a secured laptop and prohibit making copies), due diligence still cannot be overlooked. Ensuring the proper maintenance of records on an ongoing basis is critical. Where access to records is prohibited, successor tax preparers should refer to the ethical guidance regarding the use of estimates as delineated in SSTS 4, Use of Estimates.

虽然对以前的填表人记录的审查可能会受到监管指导和公司政策的限制(例如,许多公司只允许在安全笔记本电脑上访问记录,并禁止复制),但仍不能忽视尽职调查。确保持续正确维护记录是非常关键的。如果禁止查阅记录,继任纳税申报人应参考SSTS 4“估算使用中所述的估算使用道德指南。

Record Retention and Destruction


Each individual firm is bound by record retention rules mandated by its state’s board of accounting. Despite this, many firms do not utilize a standard record retention and destruction policy. As professional relationships with clients develop, CPAs should articulate the firm’s record retention and destruction policies, preferably in the engagement letter. It is suggested to do this for all clients annually and notify clients at the time the firm decides to purge records.


Client Termination


 CPAs who decide to terminate a relationship should always use a termination letter.


Reasons for terminating a client can include the following:


· ▪ Conflicts of interest;

· ·▪ 利益冲突;

· ▪ Unethical behavior by the client;

· ·▪ 客户的不道德行为;

· ▪ Refusal to adhere to the tax preparer’s advice;

· ·▪ 拒绝遵守纳税申报人的建议;

· ▪ Repeated nonpayment of professional fees;

· ·▪ 多次拖欠专业服务费用;

· ▪ Incomplete, messy, or lacking records;

· ·▪ 不完整、凌乱或缺乏记录;

· ▪ Continuous disrespect of the staff and the partners;

· ·▪ 对员工和合作伙伴的持续不尊重;

· ▪ Engagements outside the CPA’s or firm’s comfort level; and

· ·▪ 超出注册会计师或公司舒适水平的业务;以及

· ▪ Frequent last-minute demands for services.

· ·▪ 经常在后关头要求提供服务。

CPA firms should screen all clients annually and, presuming the above characteristics apply, consider terminating at least one. Based upon the authors’ experience, making termination a policy increases the likelihood that deserving termination will actually be carried out rather than merely debated.