Tax Return Acceptance & Disengagement Policy
Effective 2026-10-27
This policy sets the standards under which GHL Financial Services accepts, continues, or declines individual, business, and fiduciary tax return engagements. We prepare accurate returns from the information the taxpayer provides and exercise reasonable professional diligence under applicable tax law and ethical standards.
Documentation is available
We generally accept a return when the client provides records sufficient to prepare it, including:
- Tax documents (W-2s, 1099s, K-1s, and similar forms)
- Financial statements
- Trust or entity documents, when applicable
- Prior-year returns, when available
- Supporting documentation for deductions and credits
The information appears reasonable
The information provided:
- Is internally consistent
- Does not contain obvious errors
- Can be reasonably reconciled to available records
- Does not raise significant unanswered questions
The client cooperates
The client:
- Responds to requests for information
- Answers questions truthfully
- Provides requested records within a reasonable timeframe
- Understands that ultimate responsibility for the accuracy of the return remains with the taxpayer
A reasonable filing position exists
The position taken on the return:
- Is supported by applicable tax law
- Has a reasonable basis
- Can be explained and documented if questioned by a taxing authority
Trust returns (Form 1041)
For Form 1041 engagements we generally require the records below. We are engaged to prepare tax returns, not to give legal opinions on the validity of a trust or other legal structure.
- A copy of the trust agreement and all amendments
- EIN assignment documentation
- Trustee information
- Accounting records
- Bank and investment statements
- Distribution records
- Prior-year returns, if available
Returns that need additional review
We may accept a return with additional review when it involves:
- Complex trust taxation
- Grantor or non-grantor trust determinations
- Significant carryovers
- Multi-state filing issues
- Unusual deductions
- Novel legal positions
What additional review involves
In those situations we may do any of the following. Additional fees may apply.
- Request additional documentation
- Conduct additional research
- Consult with outside advisors
- Ask the client to obtain a legal opinion from qualified counsel
When we decline or withdraw: insufficient documentation
We will decline or withdraw from an engagement when documentation is insufficient, for example when:
- Records are incomplete
- Income cannot be verified
- Books and records are unavailable
- Documentation appears unreliable
When we decline or withdraw: the proper tax treatment cannot be determined
For example, when there is:
- Insufficient information about the status of a trust
- Unclear ownership of assets
- No way to determine the reporting requirements
- A material question that remains unanswered
When we decline or withdraw: false or misleading information
For example:
- Intentional omission of income
- Falsified documents
- Misrepresentation of facts
- Requests to report information known to be incorrect
When we decline or withdraw: unsupported deductions
For example:
- Personal expenses characterized as business expenses
- Personal expenses characterized as trust expenses
- Deductions lacking reasonable support
- Positions lacking legal authority
When we decline or withdraw: refused requests
When the client refuses a reasonable request, for example when the client:
- Refuses to provide supporting documents
- Refuses to answer questions
- Refuses to sign an engagement letter
- Refuses to sign a representation letter when requested
When we decline or withdraw: professional judgment
We reserve the right to decline or discontinue services when:
- The engagement presents excessive professional risk
- We cannot support positions required to complete the return
- The engagement would violate professional standards or ethical obligations
Trust engagements we decline or end
We are likely to decline or end a trust engagement when:
- The trustee cannot explain how the trust operates
- Trust activity cannot be distinguished from personal activity
- Trust and personal funds are commingled
- Significant personal expenses are treated as trust expenses without support
- The trust's tax positions rest solely on promotional materials rather than documentation or authority
- The requested reporting cannot be reasonably supported
Our role
Our role is to:
- Prepare tax returns based on the information provided
- Exercise reasonable professional diligence
- Ask questions when information appears incomplete or inconsistent
- Apply tax law to the facts presented
What our role is not
Our role is not to:
- Audit taxpayer records
- Guarantee the validity of a legal structure
- Guarantee the outcome of an IRS examination
- Create, draft, or administer trusts, or serve as legal counsel on trust formation or administration
Guiding principle
If we can reasonably understand the facts, obtain adequate documentation, and support the reporting position under applicable tax law, we will generally prepare the return. If we cannot, we will request additional information or decline the engagement.
Contact
Questions about whether a return fits this policy can be sent through the contact form, without attaching sensitive records.
Use the contact form