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Your 2026 Engagement Letter Needs These Three Clauses

The 2026 engagement letter should explicitly cover §199A QBI documentation, §174 R&E capitalization, and digital-asset disclosure — clients who push back are the ones who need it most.

The 2026 engagement letter is the cheapest insurance the practitioner carries all year. Three clauses cover the ground that has shifted in the last twelve months and that clients will not volunteer to discuss.

1. §199A QBI documentation clause

The client agrees to provide the records the practitioner needs to substantiate the §199A deduction: W-2 wages paid, UBIA of qualified property, and the SSTB determination for any trade or business above the threshold. Without this clause, a §199A claim that fails the W-2 wage test is a practitioner-side exposure on a return the client signed off on.

2. §174 R&E capitalization clause

Specify whether the practice absorbs the §174 R&E capitalization adjustments for clients with research or development spend, and whether those expenses stay on a §1.263A-1 UNICAP method or move to a §174-only treatment. The 2022–2025 transition rules and the 2026 changes are now both in play for any return with multi-year R&E carryforwards.

3. Digital-asset disclosure clause

The client confirms whether they held, sold, exchanged, or received any digital assets during the year and agrees to the §6038 virtual-currency question on the Schedule B of Form 1040. Yes/no ambiguity on the disclosure is the most common IRS-issued summons trigger solo practices see in a four-year cycle.

Closing

All three clauses are one-paragraph additions to the standard letter. Solo practitioners reviewing their own engagement letters against this post can copy the language verbatim — and ship it before the next client signs.

Related posts

A solo retainer that survives the year-2 IRS notice cycle is a retainer whose engagement letter split notice response out of the base fee before the first CP2000, CP2501, or Letter 2201 landed. How to price the per-engagement scope, where flat-fee vs. hourly each wins, and what Treasury Circular 230 §10.35 requires on every written deliverable.

CP2000, CP2501, and Letter 2201 arrive in year 2 — and each one absorbs two to four unpriced hours from the base retainer. Here is how to run the retention math on recurring clients, price a notice-response add-on, and keep Circular 230 §10.35 diligence from eroding the practice margin.

The Q4 estimated safe-harbor under IRC §6654 and the §174 R&E capitalization rule can be reviewed on the same solo-EA planning record in Q4. The four-step workflow on /tax-planning is presented as a practitioner-review aid, not a Circular 230 conclusion or a promise of time saved.

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