Do we need to witness the client signing T183 or he/she can sign away from my sight? How will I know that this is signed by the right person?
How about:
- At some time prior to accepting the client you would have met them and verified their identity with the appropriate documentation
- Prior to preparing their T1, you would have obtained their signature on your engagement letter for the year
- After completing the T1 and prior to efiling, you would have securely handed or otherwise securely delivered the T1 / T183 to that client (only), ensuring that no other person or party had access to view his/her protected personal information
- After completing the T1 and prior to efiling, you would have compared the signature on the engagement letter with the signature on the T183
I can’t witness my clients signing their T183 forms as most of them don’t even live in the same city as me. My client base is international. I take it on trust that the right person is signing it although the T183 is for the CRA not me. I don’t obtain engagement letters from clients for personal returns but I would notice if their signature varied from year to year on the T183’s I suppose.
This is over the top to worry about. If anyone is.
Some thoughts that Professional Accountants might {be required to} consider in the management and organization of their tax workflow:
A) CRA efiler requirements:
https://www.canada.ca/en/revenue-agency/services/e-services/e-services-businesses/efile-electronic-filers/eligibility.html#elfl
“…To protect your interests and the integrity of our tax system, take proper care to verify the identity of your client. …”
and
“… Make sure your client completes and signs Form T183, Information Return for Electronic Filing of an Individual’s Income Tax and Benefit Return before transmitting the return…”
B) CPA Provincial Code Of Ethics requirements
C) Income Tax Act
D) PIPEDA (and its Provincial counterparts)
E) PCMLTFA
F) KYC
It is not accurate to say that “the T183 is for the CRA, not {the tax preparer}”, since the T183 is the legal instrument which AUTHORIZES THE TAX PREPARER to efile that specific return. Without it, the tax preparer has no authority to efile it.