Use of Disclaimers on Taxation Engagements

Last Revision: 8/31/2016

CPA Handbook Section 9200.03 states:

This Section does not apply to financial information presented solely in, or incorporated by reference in, government-prescribed tax or other forms such as corporate, trust or personal income tax return forms. Financial information incorporated by reference would only be excluded from this Section when it does not purport to convey the financial position and the results of operations of the enterprise. Financial information excluded from this Section would be accompanied by a disclaimer from the public accountant stating, for example "prepared solely for income tax purposes without audit or review from information provided by the taxpayer." However, a public accountant may decide to accept an engagement to issue a Notice to Reader on such financial information. In that case, the requirements of this Section apply.

As a result, practitioners should use the appropriate tax disclaimer ("prepared solely for income tax purposes without audit or review from information provided by the taxpayer") on financial information included in tax filings such as the GIFI (Schedules 100 and 125) or personal tax schedules such as the T776 Statement of Real Estate Rentals or the T2125 Statement of Business or Professional Activities especially when copies are provided to the client.  Most tax preparation software includes options to help practitioners insert such disclaimers on the relevant schedules.  If you have any questions on how this can be done you should consult your tax preparation software provider.

For information on the restriction on use of disclaimers under the new compilation standard (CSRS 4200) please see this document - CSRS 4200 Compilation Engagements and Disclaimers.

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