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One Team, One Heartbeat: WCG Engagements Requires A 7216 Consent
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One Team, One Heartbeat: WCG Engagements Requires A 7216 Consent
Earlier this year we described a Reset With Intention, our move away from administrative work and toward the advisory work that actually changes outcomes. Part of that reset was bringing our India team fully under the WCG umbrella as direct employees rather than contracted labor through an agency.
Here is the next step, and it is a bigger one.
Over the next few weeks, we will be asking every client to sign a Section 7216 consent authorizing us to share tax return information with our India team. Going forward, it becomes part of how we start every engagement, and we will ask for it before we open your ShareFile folder and before we send an engagement letter.
For most of you this is a signature and nothing more. For a small number of clients who would rather not sign it, we understand, and we will help them find another firm.
We know how that reads. Let us explain why we got here.
We Can No Longer Run Two Firms
For years we offered an unspoken second version of WCG. If you declined the consent, we walled your file off, restricted permissions, and routed your work exclusively to our United States staff.
It sounds accommodating. In practice it meant maintaining two workflows, two permission structures, and two versions of every process, forever, with the exceptions multiplying as we grew. It distorted who could work on what for reasons that had nothing to do with skill or availability. And it quietly told twenty-three of our own colleagues that a portion of the firm was off limits to them, which meant a ceiling on their careers that we had no good way to explain. There are glass ceilings without explanation- this is no different.
Complexity is where mistakes live. Every exception is a permission setting that has to stay correct across staff turnover, new software, and new tools. If you actually care about protecting client data, and we do, the honest move is fewer exceptions, not more.
Other Firms Charge More, We Never Did
Some firms charge more if you decline the consent. The reasoning is not crazy. Offshore support genuinely makes a firm more efficient, and declining it genuinely costs them something.
But pricing a privacy decision turns it into a toll booth, and that never sat right with us. So we did not do it. Clients who declined paid the same fees, waited the same amount of time, and received the same work product. We absorbed the cost quietly for years and never mentioned it. And No, we are asking for a cookie.
We are only mentioning it now because we want to be clear about what changed and what did not. What changed is that we can no longer maintain two versions of the firm. What did not change is that we were never going to make you pay for the privilege of a preference.
The Part Nobody Says Out Loud
Let us talk about why some people decline.
Occasionally the concern is jurisdictional and legitimate. Federal privacy protections are harder to enforce against a preparer outside the United States, and that is stated plainly in the consent form itself. We answer that concern with structure, and we will get to it.
But often that is not the concern. Often the concern is simply that the person is in India.
We are going to say the uncomfortable thing. Deciding in advance that someone is less trustworthy because of where they were born is not risk management.
If your concern is enforceability, cybersecurity, access controls, or what happens when information crosses a border, those are fair questions and we should answer them.
But if the objection begins and ends with the fact that the person is in India, that is something different. A country name is not a security control, and birthplace is not a proxy for trustworthiness. Yeah, those are some heavy words.
We have watched thoughtful, decent people apply a standard to Ahmedabad that they would never apply to Ohio. We are no longer willing to organize our firm around that distinction.
We Are All Already Doing This
While writing this post, I was on the phone with the fraud department at Chase. I was trying to put a $113,000 invoice from Canopy, our workflow software, on a credit card, which is exactly the kind of transaction that trips every alarm a bank has. The representative who cleared it was in Mumbai.
Sit with that for a second. Not billing. Not general customer service. Fraud, on a six-figure charge. The department whose entire job is deciding whether a large and unusual transaction is legitimate, staffed by a person on the other side of the world, with full visibility into an account file that contains Social Security numbers, dates of birth, and addresses.
Nobody sent me a form. Nobody asked whether I was comfortable. Then again, I trust WCG’s bank, and I trust their judgment about how to staff their own workflows. Which is rather the point.
If you have a credit card, a cell phone plan, a mortgage, health insurance, or an airline loyalty account, some portion of that relationship is almost certainly handled outside the United States. Customer service, claims processing, mortgage servicing, medical billing and coding, fraud review, software development, and back-office reconciliation have been globally distributed for decades across banking, telecom, insurance, and healthcare.
Your bank generally does not need your affirmative, geography-specific permission. Your insurer did not send you a form. Your phone carrier did not name the entity, publish its office location, or tell you who screens the people handling your account.
The difference is the IRS. Section 7216 says that if we pass your tax return information, including your Social Security number, to someone outside the United States in connection with preparing your tax return, we need your signed consent first.
There are privacy rules for banks and insurers too. But Gramm-Leach-Bliley gives you a notice, not a signature line, and the opt-out it provides has nothing to do with geography. No regulator has ever told your credit card company to obtain your affirmative permission before a representative in another country opens your file. They just disclose it in microfont on page 144 of the terms and conditions.
So the honest question is not why nobody watches the banks. It is why tax return preparation is one of the unusual consumer relationships where the law decided the border itself was worth your affirmative signature.
We are not complaining about the rule. We follow it, and we think transparency is the right instinct.
Not A Vendor. They Are Teammates
We did not sign a contract with an offshore processing factory. We built our own subsidiary and hired our own team.
Several are Chartered Accountants, a credential that everyone who holds both a CA and a CPA insists is the harder of the two. Several are Enrolled Agents, which is worth pausing on. The EA credential comes from the IRS itself, and there is no citizenship or residency requirement attached to it. The same federal government that requires your signature before tax return information crosses a border also licenses tax professionals who live on the other side of it. The rule was never about whether the person is qualified. It is about the border. Ah, the dichotomy is sooooooo interesting.
Back to teammates…
We fly there. They fly here for our firmwide meetings in December. We have met spouses. We have met children.
Every WCG employee is background checked before day one, and we run credit and financial screening on top of that, repeated every two years. Most CPA firms do neither.
Our India team is the more heavily vetted half of this firm, not the less.
This Is What Trusting WCG Means
A CPA working remotely from a spare bedroom in another state, who has never been background checked, is not inherently safer than a WCG employee in Ahmedabad who is screened every two years and works in a locked office with a biometric scanner.
Trust is earned through practice, not passport. It comes from hiring standards, training, oversight, and accountability. Every one of those things is ours to control, and the same WCG standards follow the work whether it happens in Colorado Springs, Mitchell, Laramie, or Ahmedabad.
You are not being asked to trust strangers. You are being asked to trust the firm you already hired, making the same decisions about the same kind of people. No different than Chase or Verizon. The building is just farther away. Like really far- 28 hours of travel and that is pushing the connections. Who wants another blog post?
The Net Net
The consent is a standalone form, separate from your engagement letter. It runs for seven years, so this stops being an annual chore. You can withdraw it prospectively at any time. If you do, we would not be able to continue preparing your tax returns, and because our accounting and advisory work is built around clients whose tax returns we prepare, those engagements would wind down as well. Our full security and privacy procedures are published here.
And if after all of that you would rather work with a firm that operates entirely within the United States, we understand and we will help you make the move. No hard feelings. We would rather tell you clearly at the beginning than manage around it quietly for years.
We are loud and proud about who we are. This is who we are.
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