Remote Work and Circular 230
07/29/2024
By Kathy Ploch, CPA-Houston
The traditional landscape of working as a tax professional has changed. Today’s practitioners have more responsibilities than ever before due to the increased usage of remote workers, social media, technology, cybersecurity and AI. It begs the question – does remote work compromise compliance with Circular 230? Does your firm have the necessary policies and procedures in place to exercise due diligence?
In a recent presentation before TXCPA’s Relations with IRS Committee and other tax preparer organizations, IRS Office of Professional Responsibility Attorney Advisor Laura Zelman shared that tax professionals must assess and adjust their obligations under Circular 230 to encompass these changes. Several Circular 230 standards, as well as Internal Revenue Code statutes, can be triggered when a firm uses non-traditional work arrangements.
Firms should implement a structure that provides for appropriate supervision of remote workers – especially new employees – to ensure competency, due care, document management, sharing procedures to safeguard taxpayer data, along with other confidentiality concerns of any remote work.
Treasury Department Circular 230 has not been revised since June 2014. It would be a good idea for tax professionals in August to review Circular 230 to ensure that their professional responsibilities are being met with these new changes in our work environment.
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