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It’s time to get your WISP in order

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Tax Season 2025 is approaching and, in case you missed it, recent updates to the Written Information Security Plan requirements have introduced additional complexities to the process. It’s crucial for accounting firms and tax preparers to reassess their current strategies with these changes in mind. The implications of non-compliance are significant, with potential consequences that could significantly impact your business. As we approach tax season, make sure you stay informed and ensure your WISP is robust and up to date.

WISPs and PTINs

The Preparer Tax Identification Number renewal and WISP compliance connection aren’t new. However, recent IRS modifications have expanded their scope and changed basic security protocols into more comprehensive requirements that demand careful attention and regular updates. 

That means every year, when you check off “WISP” before the December PTIN renewal deadline, it’s critical to make sure your practice is compliant with the latest changes. 

In the last round of modifications, the IRS mandated:

  • Enhanced risk assessment protocols:
  • Stricter data encryption standards;
  • Comprehensive incident response planning: and,
  • Expanded employee training requirements;

Consequences of noncompliance

The WISP requirement aligns with the FTC’s Safeguards Rule and IRS guidelines on protecting taxpayer data. It’s not just a regulatory requirement; it’s a crucial step in safeguarding sensitive client information and maintaining professional integrity.

“The Gramm-Leach-Bliley Act (GLBA) is a US law that requires financial institutions to protect customer data,” says IRS Publication 5708. “In its implementation of the GLBA, the Federal Trade Commission (FTC) issued the Safeguards Rule to outline measures that are required to be in place to keep customer data safe. Under the GLBA and Safeguards Rule, tax and accounting professionals are considered financial institutions, regardless of size. A requirement of the Safeguards Rule is implementing and maintaining a WISP. Your WISP must be written and accessible.”

Failing to have a WISP in place can result in:

  • Inability to renew your PTIN, affecting the ability to prepare tax returns for clients;
  • Legal penalties and disciplinary actions by the IRS; and,
  • Increased vulnerability to data breaches, which can lead to financial and reputational damage.

Though this might seem overwhelming, there is good news. To help simplify the road to compliance, several organizations offer WISP templates with varying features and levels of specialization. Some of these tools are free, some are not, some are made for accountants while others are more general, and some are specifically IRS compliant while others are partially so, but all can be used to help get a handle on WISPs. They include:

  1. IRS Publication 5708 
  2. Practice Protect 
  3. CPACharge 
  4. SANS Institute 
  5. AICPA-CIMA 
  6. Tech4Accountants
  7. Rightworks WISP

Compliance timeline

The PTIN renewal deadline of December 31 serves as a critical checkpoint for WISP compliance, but effective security planning requires a year-round commitment. Firms should begin their review and update process well in advance of the deadline to ensure adequate time for implementation, testing, and staff training. 

Key compliance elements:

  • Annual WISP review and updates with quarterly assessments of emerging security threats;
  • Comprehensive documentation of all security protocols, including access controls and data handling procedures;
  • Regular employee training sessions, with mandatory updates for new hires and refresher courses for existing staff;
  • Incident response plan testing through simulated security breaches and response drills;
  • System security audits covering both internal networks and third-party vendor integrations;
  • Regular backup testing and disaster recovery plan validation; and,
  • Periodic review of user access privileges and authentication protocols.

Your clients deserve secure data

A current, compliant security plan represents more than regulatory compliance—it demonstrates your firm’s commitment to protecting client data and maintaining professional standards. How you handle your clients’ sensitive financial and personal information is fundamental to your firm’s relationships and reputation.

The most successful firms approach WISP compliance not as a burden but as an opportunity to strengthen client relationships and differentiate their services. 

So, as we approach Tax Season 2025, ensure you remain up-to-date, compliant and secure with your firm’s data. This is not only a critical aspect of professional tax preparation services but also a standard your clients rightfully expect.

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Accounting

In the blogs: On the horizon

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Crypto’s future; sobering CTC; inside and outside; and other highlights from our favorite tax bloggers.

On the horizon

  • Withum (https://www.withum.com/resources/): President-elect Trump has proposed several projects to boost the crypto sector, including dispensing capital gains tax for Bitcoin transactions and building a centralized Bitcoin holding account (a strategy reminiscent of America’s domination during the dot-com years). More clearly governed and with the support of the government, the crypto market could significantly increase in 2025.
  • Tax Vox (https://www.taxpolicycenter.org/taxvox): In 2025, the Tax Policy Center estimates that 17 million children younger than 17 will receive less than the full value of the Child Tax Credit because their parents earn too little. Most of these children also live in families that earn at least $2,500, the required minimum for any CTC beyond taxes owed. Congress has options when it debates the future of the CTC.
  • Institute on Taxation and Economic Policy (https://itep.org/category/blog/): As Congress negotiates federal funding during the lame-duck session, lawmakers would be wise to remember that stripping funds from the IRS costs more than it saves. 
  • Dean Dorton (https://deandorton.com/insights/): Next year could be a big one for the M&A market. A look at key metrics good and bad, from lower borrowing costs and thawing credit to valuation gaps and regulatory scrutiny.
  • Avalara (https://www.avalara.com/blog/en/north-america.html): Canada gets ready to “join the sales tax holiday fun.”
  • Sikich (https://www.sikich.com/insights/): Sikich has entered into an agreement to acquire the federal contracts of Cherry Bekaert Advisory LLC supporting the U.S. Patent and Trademark Office. 
  • HBK (https://hbkcpa.com/insights/): Reclassifying cannabis to Schedule III could expand access to banking, insurance, and other services for cannabis businesses. It may also ease the financial burden of Sec. 280E, which prohibits cannabis companies from taking standard business deductions due to marijuana’s current Schedule I status.
  • U of I Tax School (https://taxschool.illinois.edu/blog/): Interesting note on the beneficial ownership information reporting suspension: It invalidated much coursework and time in many tax schools this fall.

Good moves

  • Taxing Subjects (https://www.drakesoftware.com/blog): Preparing for the real season coming in the spring, from more IRS notices to high-net-worth clients to using artificial intelligence responsibly in your practice.
  • Canopy (https://www.getcanopy.com/blog): The importance of accountant-client privilege, the challenges in this age of technology and complex regulations, and how an accounting-based CRM platform is fundamental.
  • Turbotax (https://blog.turbotax.intuit.com): The “Moves That Matter” series kicks off with Drew, a lover of the outdoors from Montana. Interesting model in how to write a customer profile.
  • MBK (https://www.mbkcpa.com/insights): Estate planning is in many ways a big contingency plan. What about contingency plans for the beneficiaries?
  • Gordon Law (https://gordonlawltd.com/blog/): ‘Tis the season to tell them to stop sputtering: Why are bonuses taxed so heavily?

Virtual realities

  • Virginia – U.S. Tax Talk (https://us-tax.org/about-this-us-tax-blog/): How the “Bitcoin Jesus” now finds himself in a legal maelstrom after being arrested in Spain on U.S. charges of mail fraud, tax evasion and filing false returns.
  • Don’t Mess with Taxes (http://dontmesswithtaxes.typepad.com/): As internet betting continues to explode, a look at suggested tax rates of 15% to 25% of gross gaming revenue for new states where those feeling lucky can put their money down with a click.
  • TaxConnex (https://www.taxconnex.com/blog-): Holiday shopping season offers probably the year’s golden chance for your online biz clients, not only through sales on their own sites but also through household-name marketplace facilitators like Amazon. The glistening-once-again season also offers a big danger for your clients to ignite economic sales tax nexus.

Lowering the barter

  • Tax Foundation (https://taxfoundation.org/blog): The combined effect of net smuggling of cigarettes into U.S. states was a loss of more than $4.7 billion in forgone excise tax revenue in 2022. The annual effect of cigarette smuggling is significant, but the cumulative impact of annual smuggling from 2007 to 2022 demonstrates the severity of the issue when left to fester.
  • Mauled Again (http://mauledagain.blogspot.com/): “Analyzing the Federal Income Tax Consequences of a Crappy Barter Proposal.” Heavy on the “crappy.”
  • John R. Dundon II EA (http://johnrdundon.com/blog/): What to remind clients in biz partnerships about the difference between inside and outside basis. 
  • Boyum & Barenscheer (https://www.myboyum.com/blog/): What to remind biz-owner clients about the good and bad of retained earnings.

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Accounting

KPMG grows global revenue to $38.4 billion

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KPMG International reported annual aggregated revenues of its member firms globally grew 5.1% to $38.4 billion for the fiscal year ending Sept. 30, 2024.

The 5.1% increase over fiscal year 2023 was in local currency, and measured 5.4% in U.S. dollars.

The Big Four firm attributed this growth to its “collective strategy” and multibillion-dollar investments in aligned global priorities, while supporting clients through disruptions like artificial intelligence and shifting environmental, social and governance priorities. 

The firm reported that tax and legal services grew by 10%, which the firm said was driven by client demand for its AI-enabled managed service and transformation capability, legal capability, and helping clients navigate global tax reform. KPMG also grew audit 6% and advisory 2%. 

Last year, KPMG announced a U.S. $4.2 billion investment plan over three years as part of its collective strategy to build trust and drive growth, with over U.S. $1.7 billion invested across the KPMG network in FY24, with a focus on technology and AI, talent and ESG.

The offices of KPMG LLP in the Canary Wharf business and shopping district in London
The offices of KPMG LLP in the Canary Wharf business and shopping district in London

Simon Dawson/Bloomberg

KPMG grew its headcount by 1% to 275,288, which included targeted hiring in areas like tax and technology. 

In terms of KPMG’s regional growth, the Europe, Middle East and Africa region was up 8%, the Americas up 4%, and Asia Pacific up 1%.

The firm also noted it has continued to invest in ESG services due to client demand, and previously addressed its commitment to becoming more responsible within its own business in the firm’s “Our Impact Plan” report.

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Accounting

FASB proposes ASU on environmental credits

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The Financial Accounting Standards Board today proposed an Accounting Standards Update  related to environmental credits and environmental credits obligations.

The changes in the proposed ASU aims to improve the understandability of financial accounting and reporting information about environmental credits and environmental credit obligations, and improve the comparability of that information by reducing diversity in practice.

Financial Accounting Standards Board offices with new FASB logo sign.jpg

Patrick Dorsman/Financial Accounting Foundation

Stakeholders noted that entities are increasingly subject to emissions-related government mandates and regulatory compliance programs, which often results in obligations that are settled with environmental credits. In addition, some entities voluntarily purchase environmental credits from third parties. Stakeholders also noted that generally accepted accounting principles does not provide specific guidance on how to recognize and measure this activity, which results in diversity in practice. 

The proposed ASU provides recognition, measurement, presentation and disclosure requirements for all entities that purchase or hold environmental credits or have a regulatory compliance obligation that may be settled with those credits. 

However, as the FASB’s role is to establish and improve financial accounting and reporting standards, this proposal only addresses amounts reported in financial statements. Measuring or tracking an entity’s voluntary emissions initiatives or actual greenhouse gas emissions are not addressed by the FASB or these proposed amendments. 

The FASB is accepting review and input until April 15, 2025. The proposed ASU and information on how to submit comments is available at www.fasb.org

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