RubinBrown Team Member Manual

POLICY CONTINUED Policy Title: Policy Number:

Section: Policies for Signing Tax Returns 1208

Risk Management

II. ASSIGNING RETURN SIGNERS

A. General Requirements 1. Firm Policy Determines Return Signer – The individual “who has the primary responsibility for the overall substantive accuracy of the preparation of the return” will be determined according to the Firm’s policies described herein. 2. License Requirement – Only licensed CPAs and attorneys with tax expertise (“tax attorneys”) may sign tax returns. 3. Qualified Manager – A licensed manager in the Tax Services Group or Entrepreneurial Services Group may sign tax returns at the engagement partner’s discretion. 4. Engagement Partner/Manager – In general, the engagement partner, that is, the individual who has primary responsibility for the client relationship, will be the return signer. However, another qualified partner or manager may be designated the return signer at the engagement partners discretion. B. Situations Where Engagement Partner May Not Be Return Signer 1. Engagement partner NOT a CPA – If the engagement partner is not a CPA or tax attorney, unless the assignment of the return signer is covered under another guideline, the individual who will sign the return will be a CPA or tax attorney selected by the engagement partner, taking into account that individual’s expertise and familiarity with the client. 2. Specialty/Complex Returns – If the engagement partner does not possess the specialized technical expertise to ensure the overall substantive accuracy of the return, the engagement partner should identify a different individual who possesses the expertise to be the approved signer. III. ALIGNMENT OF ASSIGNED AND ACTUAL RETURN SIGNERS The assignment of tax return signers under the guidelines described above represents the Firm’s indication of the individual “who has the primary responsibility for the overall substantive accuracy of the preparation of our tax returns.” Accordingly, to remain in compliance with IRS regulations, there must be alignment between the actual return signer and the return signer identified under these policy guidelines. IV. SUBSTITUTE RETURN SIGNERS If the originally assigned tax return signer is unavailable to sign a return, another individual may sign the return, provided such individual meets the above described policy guidelines and further provided that such individual reviews the entire preparation of the return as required under IRS regulations.

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