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Red flag

Adviser not named on the claim

Where the claim form has a place for the preparer and the adviser leaves it empty, ask why. There may be a reason. There is also a form that asked.

A red flag is a reason to ask more questions. It does not mean an adviser has done anything wrong. This page describes a practice in general terms and is not about any particular firm.

When it is a problem

  • The form in your country asks for the preparer's details and the adviser prefers not to give them.1Source 1What the claim form, or the return it is attached to, asks about the people who prepared it: Canada Revenue Agency, Guide T4088, Part 9 "Claim preparer information" (Form T661), and Income Tax Act section 162(5.1) to (5.3) (Canada); Internal Revenue Code section 6695(b) and (c), 26 CFR 1.6109-2 and IRS, Instructions for Form 6765 (United States); HMRC, "Submit detailed information before you claim Research and Development (R&D) tax relief" and manual CIRD182000 (United Kingdom). More detail on your country page.
  • The adviser prepared the claim but it is filed through your accountant, and only the accountant's name appears.
  • You are told that naming is unnecessary without being told what the form actually asks.
  • The adviser's reluctance comes with other signs: no references, no named people, no willingness to show you the claim.

When it is not a problem

  • The form in your country has no preparer section, so there is nowhere to be named.1Source 1What the claim form, or the return it is attached to, asks about the people who prepared it: Canada Revenue Agency, Guide T4088, Part 9 "Claim preparer information" (Form T661), and Income Tax Act section 162(5.1) to (5.3) (Canada); Internal Revenue Code section 6695(b) and (c), 26 CFR 1.6109-2 and IRS, Instructions for Form 6765 (United States); HMRC, "Submit detailed information before you claim Research and Development (R&D) tax relief" and manual CIRD182000 (United Kingdom). More detail on your country page.
  • The adviser's role was limited, such as reviewing a claim your own team prepared, and the form asks about the preparer.
  • Your accountant files all your returns and the adviser's involvement is disclosed to the tax authority in another way the form provides for.
  • The adviser is named in the engagement letter and the correspondence, and the form simply does not ask.

What to do

  1. Find out what the claim form in your country asks about preparers, on the country pages.
  2. Ask the adviser whether they will be named where the form asks, and if not, why not.
  3. Ask who signs the claim and who the tax authority will contact with questions.
  4. Keep the engagement letter and the correspondence with the claim, so the adviser's role is on record whatever the form says.

Sources

  1. What the claim form, or the return it is attached to, asks about the people who prepared it: Canada Revenue Agency, Guide T4088, Part 9 "Claim preparer information" (Form T661), and Income Tax Act section 162(5.1) to (5.3) (Canada); Internal Revenue Code section 6695(b) and (c), 26 CFR 1.6109-2 and IRS, Instructions for Form 6765 (United States); HMRC, "Submit detailed information before you claim Research and Development (R&D) tax relief" and manual CIRD182000 (United Kingdom). More detail on your country page.   Back
The matching green flagThey put their name on the claim

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