The tax-law layer
Before any offshore access, the 7216 regulations require written consent from the taxpayer, signed and dated, and for Form 1040 series returns the SSN must be redacted or masked unless the exception in 301.7216-3(b)(4)(ii) applies.
Offshore Accounting Data Security: Controls to Require | HelloBooks Offshore accounting data security for US firms: SSN masking under 7216, Safeguards Rule encryption and MFA, access control, and reporting obligations.
An offshore team adds distance between you and the data. The controls have to be stronger by design, because you cannot walk over and check a screen.
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Before any offshore access, the 7216 regulations require written consent from the taxpayer, signed and dated, and for Form 1040 series returns the SSN must be redacted or masked unless the exception in 301.7216-3(b)(4)(ii) applies.
Your information security program must protect customer information with encryption at rest and in transit over external networks, and require multi-factor authentication for anyone accessing an information system. Those duties do not stop at your office door; 314.4(f) requires you to contract for them with service providers and assess providers periodically.
The FTC guide also says customer information should be securely disposed of no later than two years after its most recent use to serve the customer, subject to exceptions. Put the disposal duty into the offshore contract’s exit terms.
Most offshore incidents start with a file copied somewhere it should not be. Having the offshore team work inside HelloBooks, under the six-role access model with record-level scoping and an audit trail on every action, removes the need for local copies of client books.
General information for tax and accounting professionals, not legal advice. Rules are summarised from the primary sources listed on the date shown; read the current text before relying on it.
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