── For CPA & EA practices

One missed form is $10,000.

$10,000 a form, per year, and the statute of limitations never starts. We test the triggers against the client's own statements — in January, not April.

Intake & chasing/Advisory, quantified/Cross-border first
One missed Form 8938 · penalty exposure over the year
$0$15K$30K$45K$60KINTAKE$60,000owed if misseduntil noticeNothing owedcaught at intakeJFMAMJJASOND
This red line never happens

Statutory: $10,000 initial, +$10,000 per 30 days after IRS notice, capped · IRC §6038D(d). Illustrative.

What it actually catches

Form 8938 · HSBC ****0833Workpaper draft

If this 8938 is missed

$10,000

rising to $60,000 if it is still missing 90 days after the IRS notice · IRC §6038D(d)

Threshold crossed at $87,400 · test is $75,000

hsbc_hk.pdfboc_stmt.pdf+2 more

1 field still needs you — the account holder name does not match the return.

Every figure carries the document it came from. Anything it could not trace goes to a confirmation queue, not into the draft.

The eight jobs

One cross-border engagement is, in practice, eight jobs.

Until now there was one way to staff them: hire, or have the same three people stay late through busy season. Each is real work. None of it is the work you sat the exam for.

The admin who chases
The clerk who retypes
The first-pass reviewer
The bilingual liaison
The deadline watcher
The threshold tester
The research desk
The workpaper preparer

Each one, at a large enough firm, is a salary. The agent is the eight of them at once — one engagement at a time, with a memory that does not reset between seasons. Judgment and the signature were never on this list. Those are yours.

Scenario 01 · Intake and chasing

One click from you. One link for them.

The part of busy season that costs the most hours carries the least judgment — and it is slow on both sides. Your team retypes what the client sent; the client is asked three times for the same file. You start the engagement once and the agent runs the rest of the loop. What has already landed is never asked for again.

What you do
  • Click once to open the engagement
  • Set the cadence, or leave it on automatic
  • Look at the exceptions, not the inbox
What your client does
  • Opens an encrypted link — no account, no password, nothing to install
  • Drops the whole folder in at once — no matching to a list, phone photos fine
  • Is told on the spot if something is the wrong year or unreadable
  • Comes back to the same link whenever the next statement turns up
What the agent does
  • Identifies each file by what it is, not what it is called
  • Files it against the engagement checklist
  • Sends back the wrong year, the wrong account, the unreadable scan
  • Chases what is still missing, in English or Chinese, until it lands
  • Remembers what was sent back, and asks for it precisely next season
Scenario 02 · Advisory

Eight domains, each with one number it is measured by.

Once the documents are in, the same file answers what clients actually pay for. Every domain below produces figures out of the client's own records — not a restatement of what they already told you. What those figures mean for the client is your call.

Cross-border assets and filings

LiveWhere practices start

FBAR and Form 8938 trigger tests run on each account's yearly maximum, with a field-level draft and everything it could not source marked; Form 5471 and other forms are flagged for your determination

Measured by · Penalty exposure found in January instead of April

Compliance calendar and events

Live

Every filing by date for the year, for each client and for your own practice, with the reason it applies and the consequence of missing it

Measured by · Missed deadlines: zero, and each one auditable

Cash flow and working capital

Building now

Monthly cash report and a 13-week rolling forecast, AR ageing, DSO and DPO, and the gap before it arrives

Measured by · Days from invoice to cash

Performance and benchmarks

Building now

A plain-language read of the numbers, year-over-year and period-over-period anomalies, and the same figures against the industry band

Measured by · Anomalies surfaced before the client asks

Entity and structure

Building now

What the current entity and residency setup obliges today, what an S-corp election would change in dollars, and which filings appear or disappear if it changes

Measured by · Self-employment tax difference, in dollars

Spending and pre-tax planning

Planned

Where the money actually goes by category, business-versus-personal splits, depreciation timing, and the year-end items still open with the date each one closes

Measured by · Decisions still open before Dec 31

Financing and credit readiness

Planned

A loan-readiness package, DSCR, and the document list a lender will ask for

Measured by · Weeks saved getting to a lender-ready file

Valuation, exit and succession

Planned

An annual valuation range, an exit-readiness gap list, and the data-room checklist — only the parts that can be computed

Measured by · Gaps closed before diligence starts

What ships in every domain is the same two layers: the figures, and what is off about them. The layer above — what to do about it — stays with you. That is the design, not a gap we are working around: a recommendation nobody licensed signed is worth nothing to your client, and a number your software guessed is worth less than that.

── How it is built

The model reads. It does not do the arithmetic.

Two different things get called “a number”, and the difference is the whole design. Reading a balance off a statement is a transcription — a model does that, and every figure it lifts is marked as read rather than computed, so it lands in front of you to check. Everything downstream of that reading — the totals, the threshold tests, the tax differences, the dates, the ageing — is arithmetic, and arithmetic is done in code that you can point at.

Code, deterministic

  • Totals, ageing buckets and ratios over your clients' books
  • Threshold tests, and which figure crossed which line
  • Every filing date in the compliance calendar — from the statutory rules, weekend and federal-holiday roll-forward included
  • Tax differences, and the forecast arithmetic behind a projection

Model, reading and language

  • Lifting a balance or an account number off a statement — flagged as read, for you to confirm
  • Why this rule applies to this client, in a sentence
  • What the consequence is if it slips
  • Never a total, never a due date, never whether a form is required

This is the whole reason a licensed professional can put their name on what comes out. A figure a model invented is not reviewable — you would have to redo it to trust it, and then the software saved you nothing.

The tests it applies, and where they come from

Citations on output: next

These are the published thresholds the agent tests against, with the authority for each one. It applies them; it does not decide whether a form is required. Attaching the authority to every output — so a draft leaves your desk already sourced — is the next piece of work, not something running today.

FormAuthorityTest applied
FinCEN Form 114 (FBAR)31 CFR 1010.350Combined highest balances exceed $10,000 at any point in the year
Form 8938IRC §6038D · Form 8938 InstructionsUnmarried or MFS: over $50,000 at year-end, or over $75,000 at any time. MFJ: $100,000 / $150,000. US residents who file a return.
Form 5471IRC §6038 · §6046 · Form 5471 Instructions10% or more of vote or value (§6046), or control over 50% (§6038); §6038(b) penalty starts at $10,000 per form, per year

Thresholds shown are the current federal tests for US residents and are re-checked against the instructions each filing season. The agent applies them; it does not decide whether a form is required.

── Capability expansion

The cross-border engagements you turn away today, you can take next quarter.

Most small practices run domestic work only. Cross-border clients walk in the door and get referred out, because the exposure of getting FBAR or Form 8938 wrong is not worth the fee. That is a revenue problem, not a time problem.

01

Learn

A short course on the cross-border filings — FBAR, Form 8938, Form 5471 — what triggers them, what the penalties are, and where the judgment calls sit.

02

Run it with the agent

The white-label cross-border package runs the trigger tests against the published thresholds and drafts the fields, marking every one it could not source. You review and sign.

03

Keep the client

The engagement stays in your practice instead of going to the firm you referred it to — and existing clients with overseas accounts become billable work.

Learning is the entry point; the reviewable execution package is what you actually bill against. Nothing reaches a client without your review.

What the agent does, and what you sign

This is the whole architecture, not a disclaimer at the bottom of a page. Every draft arrives with the source document behind it, a confidence level, and the fields the agent could not confirm marked as exceptions rather than filled in.

WorkAgentCPA / EA
Document extractionEvery documentReview
Missing-document detectionEvery clientHandle exceptions
Classification suggestionsSuggestedApprove
ReconciliationAgent runs itApprove exceptions
Cross-border trigger analysisFirst pass + evidenceFinal determination
Tax researchRetrievalProfessional judgment
DiagnosisDraftFinal judgment
Tax positionSupporting onlyCPA / EA
Return preparationSupporting onlyPreparer
Signature and filingNeverLicensed professional
Legal opinionNeverAttorney

Four things it will not do

  • Never a negative conclusion

    It will say a threshold appears crossed. It will not say a filing is unnecessary.

  • Never reasons about detection

    No output suggests something is unlikely to be found, and no aggressive position goes in writing.

  • Never signs or files

    Not a signing preparer. Returns, filing positions and signatures stay with you.

  • Never guesses a field

    Anything it cannot trace to a source document is raised as an exception.

Built around §7216 client consent and the FTC Safeguards Rule (16 CFR Part 314) written information security plan requirement, for which IRS Pub. 5708 is the template. Every action is logged.

Where practices start

Chasing first, because it costs the most hours and carries the least judgment — and it is what earns the document access everything else runs on. Cross-border is the advisory domain to open next: highest exposure, and the one no incumbent is pointed at for this client base. See the cross-border workflow in detail.

Bring one client file.

Last year's return and this year's statements. See the draft before you decide anything.

Start free