Third-Party Disclosures: Maintaining Client Confidentiality

Comfort Letters and Consent Forms; IRC Section 7216, AICPA and State Board Rules

Note: CLE credit is not offered on this program

A live 110-minute CPE webinar with interactive Q&A

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Thursday, October 27, 2022

1:00pm-2:50pm EDT, 10:00am-11:50am PDT

Early Registration Discount Deadline, Friday, September 30, 2022

or call 1-800-926-7926

This webinar will discuss the conflicting guidance on responding to third-party and client information requests for work papers and tax return documents. Our esteemed panel will cover requests for client documents that could unknowingly expose practitioners to liability and the exceptions to confidentiality rules, as well as provide sample consent forms for common documentation requests.


Clients and third parties frequently approach tax practitioners to disclose sensitive taxpayer information. Obvious third-party requests include subpoenas and comfort letters. Perhaps not as conspicuous, third-party disclosures that require consent include requests for work papers from a new accountant, a potential purchaser of your practice, or when the IRS makes contact.

Professionals are subject to many often conflicting sources of guidance dictating how to disseminate confidential information. These include the AICPA Rule on Confidentiality, IRC Section 7216, and state board rules. Resources are available to aid practitioners; for example, the AICPA provides sample consent forms to disclose tax return information.

Understanding consent requirements and the exceptions are complicated. Tax advisers can face legal action for providing or failing to provide client information. Advisers must understand how and when to disclose documents and client information.

Listen as our panel of professional liability experts provides appropriate responses to common scenarios, including comfort letter requests, mergers and acquisitions of an accounting practice, outsourcing accounting services, and investigations by tax and regulatory authorities for tax and accounting professionals.



  1. Third-party disclosures: introduction
  2. Professional standards governing third-party disclosures
    1. AICPA rule on confidentiality
    2. IRC Section 7216
    3. State board rules
  3. Exceptions to confidentiality
    1. Subpoenas
    2. Peer reviews
    3. Malpractice claims
    4. Consent
    5. Other
  4. Disclosure scenarios
    1. Divorce
    2. Investigations by taxing and regulatory authorities
    3. Comfort letters
    4. Accounting practice mergers and acquisitions
    5. Outsourcing tax and accounting services
  5. Best practices


The panel will cover these and other key issues:

  • When are consent forms from clients required or advised?
  • How should unannounced visits by IRS Revenue Agents be handled?
  • How should practitioners navigate conflicting IRC, AICPA, and state guidance on third-party disclosures?
  • When and how should an adviser provide a comfort letter to a mortgage lender?


Larkin, Peter
Peter J. Larkin

Wilson Elser

Mr. Larkin provides legal counsel and representation to accountants and accounting firms in connection with all aspects...  |  Read More

Raspante, John
John Raspante, CPA, CDFA, MST

Director of Risk Management


 |  Read More
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Early Discount (through 09/30/22)

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