PitBullTax News

Below is an overview of what’s new.

1. Clear Guidance on When IRC 7216 Consent Is Required

We have clarified when IRC 7216 consent is required and when it is not. When creating a new client, you can now completely bypass the IRC 7216 disclosure if it is not applicable by selecting “No” when asked whether the disclosure is required.

IRC 7216 Consent Not Required If:

• You only provide tax resolution services (e.g., OIC, IA, CNC, CSED analysis)
• You do not prepare tax returns (current or past-due)
• Taxpayer information is received directly from the IRS or the client for resolution purposes
• You use U.S.-based software, employees, and/or remote workers (PitBullTax Software is hosted and based in the U.S.)
• No taxpayer information is shared with non-U.S. persons or entities

IRC 7216 Consent Required If:

• You prepare or assist with tax returns (e.g., Forms 1040, 1120, 941)
• The same taxpayer data is used for both tax preparation and resolution services
• Taxpayer information is shared with foreign-based remote workers (including tech support or data entry)
• Taxpayer data is used for marketing or non-tax services (e.g., retirement planning, insurance products, business formation, payroll services, IRS transcript monitoring, etc.)
• Taxpayer information is shared with third parties (e.g., bankers, advisors, or affiliated businesses)

Best Practice:
If you anticipate using IRS transcripts for both resolution and tax preparation—or if you are unsure—it is safest to obtain written IRC 7216 consent upfront. This helps protect you from potential civil and criminal penalties under IRC 7216 and 6713.

2. Updated Client Disclosure Language

We have updated the wording of the mandatory IRC 7216 Disclosure and Consent sent to clients. The revised language clearly explains the use of PitBullTax Software and why the client’s signature may be required.

You may customize this language to fit your practice by navigating to:
Settings > Customizable Letters > IRC 7216 Disclosure and Consent

3. New IRC 7216 Settings Page

A new settings page is now available at:
Settings > IRC 7216 Disclosure

From this page, you can:

• Define default authorized parties (License Owner, Company Name, or another person/entity)
• Set a default consent duration of 1 to 5 years
• Choose to disable IRC 7216 consent requests for all clients
• Automatically send the IRC 7216 Disclosure and Consent upon client creation

If consent is disabled, the software will skip IRC 7216 prompts when adding new clients.

4. Bulk Sending of IRC 7216 Disclosure and Consent

You can now send the IRC 7216 Disclosure and Consent in bulk to all Individual or Business clients.

To do so:

1. Go to Clients > Individual Clients or Business Clients
2. Select all clients or choose specific ones
3. Scroll to the bottom and click “Send IRC 7216 Disclosure”

Important Note

To ensure all updates display correctly, we recommend clearing your browser cache.

If you have any questions regarding these updates, please contact our Customer Support team at 954-748-2855.