Once upon a time, life was a lot less complicated for professionals of every kind and for their clients.

Years ago, if someone asked me for some help, we could proceed immediately to discuss the situation and possible solutions. I was able and willing to help subscribers and other people who would call me with a question about some tax issue. In many cases, if they were subscribers to my newsletter, I would simply answer the question without any additional fee.

But times have changed and the lawyers have made life a lot more complicated.

The focus of my work now relates to international tax law. In order to provide anyone with specific profesional tax advice regarding any tax matter, I must now be sure that I have gotten well enough acquainted with the client to be sure the client is not seeking to use my advice to engage in any form of tax evasion or other illegal activities -- such as money laundering.

Many years ago, money laundering was something that only affected drug dealers and other criminals. Today, due to the U.S.A. Patriot Act and many other laws, nearly all financial or legal professionals such as lawyers, accountants and financial planners are subject to the complicated and very ambiguous provisions of the Patriot Act. A fundemental element of that act is a requirement to "Know Your Customer". In my case, it means, "Know Your Client".

A couple of years ago, an asset protection attorney assisted a client in establishing a variety of offshore trusts and coporations for the purpose of asset protection. As it turned out, the client used those structures to launder money -- apparently without the knowledge of the lawyer. The government gave the client an opportunity to get a lesser sentence if he would testify against his lawyer -- which he did. The lawyer is currently in jail even though he claims the client lied under oath.

In January, 2003, the IRS introduced an "Amnesty" program for U.S. taxpayers who had unreported income from foreign financial accounts. Initially, they located those accounts by getting a judge to issue a subpoena against two major credit card companies that issued international credit cards drawn on the accounts of a number of foreign banks. While the ostensible purpose of the program was to locate and prosecute individuals with unreported income, the real objective was to get those people to identify the lawyers, accountants, financial planners and other promoters of offshore financial arrangements. By targeting these professionals and promoters, the IRS would be able to locate a great many more of the people who are evading taxes and/or hiding assets offshore.

Although I don't assist taxpayers in the formation of  offshore entities, I do refer clients to various parties that are able to facilitate the formation of offshore entities or structures. There is some uncertaintly about whether the KYC rules would apply to me when my only service is the preparation of forms for tax compliance or the explanation of the law as I understand it.  However, the laws are vague and the government has become increasingly aggressive in its interpretation of these laws. I'm therefore taking the approach that I should have the requisite information about each new client.

If you wish to have my help as a tax accountant or consultant (with an emphasis on international tax law), I must require that you provide me with

• a signed engagement letter (sample consulting agreement)
  
• a complete copy of your latest personal and any business tax returns,
• a recent personal financial statement,
• a completed copy of my client questionnaire, and
• signed copies of my Disclaimer statement

In addition, I may need to meet with you at your office or in the Kansas City area to get acquainted unless my only duty to you involves the preparation of various tax returns required by your international transactions.  (If you want tax planning assistance, we need to meet.)

If you do not wish to establish a client relationship, there are two ways that I may be able to help you with answers to some questions.