Outsourcing Advisory for CPA & Accounting Firms
Jason Dinesen

Global Offshoring
Advisory

GOA
Enrolled Agent (EA) Licensed Public Accountant IRC §7216 · AICPA Ethics · FTC Safeguards
500+
CPA Firms Advised
200K+
Professionals Trained
15+
Years in Advisory
3
Service Lines

Most CPA firms offshoring work have never been told they have a compliance obligation under IRC §7216, AICPA Code of Conduct, and FTC Safeguards. Jason Dinesen gives you the clarity, the documents, and the strategic roadmap to build offshore teams that are compliant from day one.

500+
CPA firms advised on outsourcing compliance
200K+
Professionals trained on tax law & ethics
15+
Years in accounting & advisory
0
IRS enforcement actions under §7216 — but the risk is very real
Who We Serve

Built for Firms Offshoring — or Thinking About It

Whether you have 20 offshore staff or are just starting to evaluate vendors, Global Offshoring Advisory meets you where you are.

📋

Already Offshoring, No Compliance Review

You have an active offshore team but have never reviewed §7216 consent, AICPA disclosure obligations, or done formal vendor due diligence. The most common — and most exposed — position.

🔍

Evaluating Vendors, Need an Independent View

You're selecting an offshore provider and want independent assessment covering compliance, data security, operations, and talent quality — not the vendor's own pitch deck.

🏗️

Building a Captive Global Team (GCC)

Larger or PE-backed firms building owned offshore operations. Geography, entity structure, team design, and compliance from the ground up — fully guided.

Advisory Services

Three Ways GOA Helps Your Firm

View Pricing →
01
Compliance + Strategy · 2-Hr Sessions

Outsourcing Advisory

$1,198
$699
Bundle · 2 sessions + full resource pack
Book Bundle →

Two focused one-hour sessions combining everything your firm needs: the regulatory compliance session covers IRC §7216, AICPA Code, and FTC Safeguards — ensuring your consent forms, vendor agreements, and WISP are airtight. The business advisory session maps your readiness across five dimensions and delivers a scored report, team structure blueprint, and 30-day action plan. Sessions can be taken together or separately.

IRC §7216 · Rev. Proc. 2013-14 AICPA 1.150.040 · 1.700.001 · 1.700.040 FTC Safeguards · 16 CFR Part 314 Offshore Readiness Assessment Onshore-Offshore Org Design Task Delegation Framework
See full scope: regulatory coverage · readiness dimensions · 14-piece resource bundle
§7216 + AICPA + FTC 5 Readiness Dimensions 14 Resources
Regulatory Advisory
Business Advisory
Common Issues Found
Full Resource Bundle
IRS IRC §7216 — Consent & Disclosure
What qualifies as "tax return information" under §7216
Basic consent requirements for all outsourcing arrangements
Additional requirements for 1040 foreign outsourcing
Non-1040 consent: payroll, corporate, sales tax, write-up
Affirmative opt-in vs. prohibited opt-out consent forms
Electronic consent: 5-character verification requirement
Consent validity: 1-year default, multi-year best practice
Adequate data protection safeguard §301.7216-3(b)(4)
Criminal penalties (§7216) and civil penalties (§6713)
EFIN revocation risk from non-compliance
AICPA Code of Professional Conduct
1.150.040 — Must tell clients you're outsourcing (in writing)
1.700.001 — Confidential client information general rule
1.700.040 — Contract vs. specific consent: which route
1.300.040 — Vetting, supervision, and due diligence obligations
Administrative exception — what qualifies and what doesn't
State CPA board confidentiality rules (Rule 301)
FTC Safeguards Rule
Why CPA firms are "financial institutions" under GLBA
Service provider oversight obligations under §314.4(f)
WISP requirements applicable to your firm's size
Penalties: up to $100K/violation + personal liability $10K
Five Dimensions Scored in Every Business Advisory Session
People Readiness
Onshore team's delegation capability
Management bandwidth for oversight
Process documentation maturity
Communication style and norms
Change readiness and culture fit
Work & Task Mapping
Services appropriate to offshore
Tax prep vs. review vs. advisory
Bookkeeping, audit support, write-up
Client-facing vs. back-office split
Seasonal vs. year-round workflow
Structure & Integration
Org structure and team ratio design
Timezone overlap requirements
Cultural integration strategies
Performance management approach
Escalation paths and communication
Firm Readiness Factors Evaluated
Documented SOPs for outsourceable tasks
Designated onshore point of contact identified
Task-level time budgets established
Cloud-accessible and compatible tech stack
Defined review process for offshore deliverables
Seasonal capacity and surge planning approach
Most Common Regulatory Issues Jason Finds
Opt-out consent language — violates §7216, extremely common
Missing vendor name in disclosure (required for foreign outsourcing)
Consent buried in engagement letter without separate treatment
No consent at all for non-1040 work — still required
Font size below 12-point on paper consent forms
"As long as you remain a client" validity language — not permitted
Electronic consent auto-populates taxpayer name — prohibited
WISP not updated to include offshore service provider
Top Offshore Business Failure Modes Jason Helps You Avoid
Offshoring complex tasks before basic processes are documented
No onshore "champion" — offshore team works in isolation
Unclear quality expectations creating endless rework cycles
Culture clash causing communication breakdown within 90 days
Offshoring client-facing work too early in the relationship
No replacement plan when a key offshore staff member leaves
Offshoring roles that require judgment the firm hasn't transferred
No SOP documentation — offshore team can't maintain consistency

The full Outsourcing Advisory bundle includes 14 documents across both sessions — all delivered within 48 hours. Regulatory resources are compliance-ready templates; business resources are operational tools your team can use immediately.

FROM REGULATORY ADVISORY SESSION
Template
§7216 Consent Form — 1040 Work

Rev. Proc. 2013-14 compliant standalone consent form with all required elements, affirmative opt-in language, and 5-year validity.

Template
§7216 Consent Language — Non-1040

Engagement letter addendum with AICPA-recommended disclosure language for corporate, payroll, sales tax, and bookkeeping work.

Guide
Step-by-Step Compliance Action Plan

Numbered, prioritized guide: exactly what to update, what to send to which clients, and in what order — ready to assign to staff.

Guide
Annotated AICPA Sample Language

Official AICPA outsourcing disclosure language with Jason's plain-English commentary on each clause and what you must confirm.

Reference
FTC Safeguards Self-Assessment

12-point checklist to verify FTC Safeguards Rule compliance including WISP requirements and service provider oversight.

Template
Client FAQ Email Template

Ready-to-send email answering the five questions clients ask about §7216 consent — addresses every common objection.

Reference
Regulatory One-Pager

Single-page summary of §7216, AICPA Code, and FTC Safeguards with citation links — for your compliance folder.

Case Study
Before/After Consent Language Examples

Non-compliant consent annotated with violations, and a compliant version annotated with why each element works.

FROM BUSINESS ADVISORY SESSION
Report
Offshore Readiness Score Report

Your firm's score (0–100) across five dimensions, with written explanations of gaps and prioritized recommendations.

Framework
Task Mapping Template

Structured spreadsheet mapping your service lines to offshore-ready, hybrid, and onshore-only categories.

Blueprint
Onshore-Offshore Team Structure Blueprint

Recommended org structure for your specific team size, service mix, and growth stage — roles, ratios, reporting lines.

Plan
30-Day Offshore Onboarding Plan

Day-by-day action plan for your first month: before day 1, first week, and full 30-day milestone checklist.

Checklist
Cultural Integration Checklist

Practical checklist for building a cohesive onshore-offshore culture: communication norms, feedback cadence, recognition.

Case Study
Offshore Success Case Study

Real example of a CPA firm that built a successful offshore team — what they did, challenges faced, and outcomes achieved.

02
Vendor Assessment

Outsourcing Vendor Due Diligence

$1,499
$999
One-time · per vendor assessment
Schedule Assessment →

Independent evaluation of your offshore vendor across three dimensions — compliance, security, and operations — with a scored report and written recommendation. No vendor stake, no conflicts. Includes the GOA Vendor Scorecard: 70+ questions across 7 sections, scored 0–5, producing a total weighted score with Pass/Fail threshold. AICPA 1.300.040 documentation included.

IRC §7216 · §301.7216-3(b)(4) AICPA 1.300.040 Due Diligence FTC Safeguards §314.4(f) SOC 2 Type II Verification ISO 27001:2022 IRS Publication 1075 AICPA/CICA Privacy Framework
See full scope: 3 assessment dimensions · 25-point checklist · GOA Vendor Scorecard · deliverables
Compliance · Merit · Operations Full Checklist 6 Deliverables + Scorecard
Assessment Dimensions
Full Checklist
GOA Vendor Scorecard
Deliverables
Three Dimensions Scored in Every Assessment
Compliance & Regulatory
IRC §7216 adequate data protection safeguard
AICPA Code 1.300.040 & 1.700.040 obligations
FTC Safeguards Rule §314.4 requirements
GDPR / data residency compliance
IRS Pub. 1075 framework alignment
AICPA/CICA Privacy Framework
WISP documentation and approval
Client consent documentation support
Merit & Data Security
SOC 2 Type II certification status
ISO 27001:2022 certification
AES-256 encryption at rest & in transit
MFA enforced for all users
Role-based access control (RBAC)
Penetration testing frequency
Incident response plan (IRP)
Cybersecurity & E&O insurance
Operations & Talent
Staff qualifications (CPA, EA, CA, ACCA)
Vetting & hiring process rigor
Employee turnover data by city/level
L&D ecosystem & CPE access
Client references with direct contacts
Work timing & timezone overlap
Financial stability indicators
Geographic diversification & risk
Legal, Registration & Financial
Vendor registered and compliant with local laws
No active regulatory sanctions or legal proceedings
Financial stability certificate from independent CA
E&O, Cyber, and General Liability insurance verified
Data Security & Infrastructure
SOC 2 Type II certification current and valid
ISO 27001:2022 certification reviewed
AES-256 at rest, TLS 1.3 in transit confirmed
MFA enforced for all system access
RBAC and least-privilege access controls
WISP documented and management-approved
24/7 CCTV and biometric physical security
SIEM real-time monitoring deployed
Pen testing every 6 months or after major changes
Incident Response Plan with 24-hr breach notification
USB ports locked, unauthorized storage blocked
Disaster recovery tested quarterly
Workforce, Quality & Regulatory
Staff qualifications and certifications verified
Turnover data by city/role/level disclosed
Client references with direct contact details
Termination and access revocation protocols
§7216 disclosure language in vendor agreement
FTC §314.4(f) service provider obligations met
AICPA 1.700.040 contractual agreement in place
GDPR / IRS Pub. 1075 framework alignment confirmed

Every vendor due diligence engagement uses the GOA Vendor Scorecard — a comprehensive 70+ question scoring tool across 7 weighted sections. Scores are 0–5 per question with automatic aggregation, color-coded ratings, and a Pass/Fail determination. The completed scorecard becomes your AICPA 1.300.040 due diligence documentation.

Scorecard Structure
Section 1: Legal & Financial (10% weight)
Section 2: Compliance & Regulatory (25% weight)
Section 3: Data Security & Infrastructure (25% weight)
Section 4: Workforce & Expertise (15% weight)
Section 5: Quality & Process (10% weight)
Section 6: Operations & Delivery (10% weight)
Section 7: Contractual & Insurance (5% weight)
Scoring & Thresholds
0–5 per question · 70+ questions total
85–100%: PASS — Recommended
70–84%: PASS — Conditional
55–69%: MARGINAL — Caution
40–54%: FAIL — Remediation Required
Below 40%: FAIL — Do Not Engage
Critical override: Compliance section below 60% = automatic fail
What You Get
Completed GOA Vendor Scorecard (Excel)
Color-coded section ratings with heat map
Automatic Pass/Fail recommendation
Section-level gap notes from Jason
Assessor sign-off block for your files
AICPA 1.300.040 documentation language
Advisory call with Jason to review findings

Every vendor due diligence engagement delivers these documents within 48 hours — all go into your compliance files and satisfy AICPA documentation requirements under 1.300.040.

Delivered
GOA Vendor Scorecard (Excel)

Complete scored assessment across 70+ questions in 7 sections, with automatic aggregation, Pass/Fail recommendation, and assessor sign-off block.

Delivered
Scored Vendor Assessment Report (PDF)

Written narrative report covering key findings, dimension ratings, and final recommendation — suitable for partner review and firm files.

Delivered
§7216 Compliance Gap Summary

Written summary of any gaps in your vendor's adequate data protection safeguard compliance, with specific remediation steps.

Delivered
Due Diligence Documentation Pack

AICPA 1.300.040-compliant documentation confirming you conducted proper due diligence — ready to file with client records.

Delivered
FTC Safeguards Vendor Checklist

A completed FTC §314.4(f) service provider checklist confirming your oversight obligation has been met and documented.

Bonus
Vendor Interview Cheat Sheet

Structured question guide for your own vendor evaluation calls — what to ask, what to probe, and which red flags to watch for.

03
Premium · Ongoing

Global Capability Center (GCC) Consulting

$4,999
$2,999
3-session program
Inquire About GCC →

For firms ready to build a captive offshore operation rather than rely on a vendor. Jason guides you through geography, entity structure, team design, in-country compliance, and a 12-month build roadmap — across three structured sessions with deliverables at each. GCC Consulting is for firms thinking bigger than vendor relationships.

Geography & City Selection Entity Structure (EOR / Subsidiary / Branch) In-Country Labor & Tax Compliance Captive vs. Vendor Cost Analysis 12-Month Build Roadmap Leadership Model Design
See full scope: build dimensions · geography matrix · 6 program deliverables
3 Build Dimensions India vs. Philippines 6 Deliverables
Build Dimensions
Geography Matrix
Program Deliverables
Compliance & Legal
In-country labor law requirements
Data residency & privacy regulations
Tax implications of captive structure
IP ownership and data security
U.S. regulatory obligations maintained
Entity type & registration requirements
Geography & Talent
India: city-by-city talent comparison
Philippines: cost, skills, timezone
Tier 2/3 city advantages vs. metro
Talent pool size by discipline
Turnover benchmarks by location
Total cost including all-in salary
Build & Operations
EOR vs. subsidiary vs. branch model
Phase 1: pilot team (months 1–4)
Phase 2: scale & specialize (5–12 mo)
Leadership hiring & onboarding
Captive vs. vendor cost-benefit
Infrastructure & tech stack setup
India: City Comparison Overview
Mumbai / Pune: large talent pool, highest cost, higher metro turnover
Hyderabad / Bangalore: tech-heavy, mid-cost, strong accounting talent
Ahmedabad / Surat: Tier 2, lower cost, strong CPA exam culture, lower turnover
Jaipur / Indore: emerging Tier 2 hubs, competitive all-in cost structure
Smaller towns: lowest cost, highest loyalty, requires stronger L&D investment
Night shift differential: non-mandatory in India, mandatory in Philippines
Entity Structure Options
Employer of Record (EOR): fastest to start, no local entity needed, higher per-head cost
Wholly Owned Subsidiary: full control, compliance burden, 6–12 months to establish
Branch Office: simpler structure, some limitations on permitted activities
Hybrid: EOR to start, transition to subsidiary once team exceeds ~20 FTEs
Build Phase Milestones
Months 1–2: geography confirmed, entity structure decided, recruiting begun
Months 3–4: first hires onboarded, infrastructure set up, SOPs documented
Months 5–6: pilot team producing work, quality review process live
Months 7–12: scale, specialize, add leadership layer, evaluate EOR transition

Structured deliverables at each of the three sessions — you leave every call with something tangible. Six documents delivered across the engagement.

Session 1
GCC Feasibility Report

Written assessment of whether captive is right for your firm — with recommendation and rationale based on your goals.

Session 1
City Selection Matrix

Side-by-side comparison of 6–8 city options across cost, talent, turnover, infrastructure, and regulatory complexity.

Session 2
Entity Structure Recommendation

Written guidance on which entity model fits your timeline and budget, with setup timelines and cost estimates.

Session 2
12-Month Build Roadmap

Phased timeline covering hiring, infrastructure, compliance, team structure, and leadership milestones across four phases.

Session 3
Captive vs. Vendor Cost Analysis

Detailed cost comparison for your projected headcount over 3 years — total cost of ownership modeled both ways.

Ongoing
60-Day Email Access to Jason

Direct email access for follow-up questions, document review, or working through decisions post-session.

Transparent Pricing

Choose Your Advisory Level

Direct access to Jason in every engagement — no account managers, no junior staff hand-offs.

Outsourcing Advisory Bundle
$1,198
$699
2-session bundle · Regulatory + Business

  • Regulatory Advisory session (1-hr)
  • Business Advisory session (1-hr)
  • §7216 consent templates (1040 & non-1040)
  • FTC Safeguards self-assessment checklist
  • Offshore readiness score report
  • Task mapping template & team blueprint
  • 30-day onboarding plan + cultural checklist
  • 8 regulatory resources + 6 operational docs
Book Bundle →
Vendor Due Diligence
$1,499
$999
One-time · per vendor

  • GOA Vendor Scorecard (70+ questions)
  • 30-min advisory call with Jason
  • Scored 3-dimension assessment report
  • §7216 compliance gap analysis
  • FTC Safeguards vendor checklist
  • Due diligence documentation pack
  • Pass/Fail recommendation with rationale
Schedule Assessment →
GCC Consulting Program
$4,999
$2,999
3-session program

  • 3 structured advisory sessions
  • GCC feasibility report
  • City selection matrix (6–8 cities)
  • Entity structure guidance
  • 12-month build roadmap
  • Captive vs. vendor cost model
  • 60-day email access to Jason
Inquire Now →
Free Assessment

Are You Ready to Offshore?

10 questions. 3 minutes. A personalized readiness score and PDF report with your compliance stage, gaps, and next steps.

Free · Instant PDF Report

Offshore Readiness Assessment

Most firms don't know what they don't know about outsourcing compliance. This assessment scores you across four areas and sends a personalized PDF report to your inbox — with exactly where your firm stands and what to do next.

What the Report Covers
📋
Compliance Score

§7216, AICPA Code, and FTC Safeguards — where you actually stand

🔍
Vendor Due Diligence Status

Whether your vendor assessment meets AICPA 1.300.040 standards

🏗️
Team Readiness Level

Are your processes, people, and structure ready to offshore?

🗺️
Stage Placement + Roadmap

Which of 3 stages you're in and prioritized next steps for your firm

Free Resources Delivered With Your Report
Offshore Readiness Summary PDF (personalized, scored)
Sample GOA Vendor Scorecard — preview of 70+ parameters
§7216 Quick Reference Guide for CPA Firms
Recommended next steps based on your specific score
GOA advisory session recommendation matched to your stage
Start the Assessment →

Get Your Free Report

Enter your details to unlock the assessment and receive your personalized PDF instantly.

No spam. Report delivered to your email.
Takes about 3 minutes.

Readiness CheckQuestion 1 of 10
Does your firm currently use any offshore or outsourced staff for accounting, tax, or bookkeeping work?
Have you obtained IRC §7216 written client consent for offshore disclosure of tax return information?
Has your firm conducted formal due diligence on your offshore vendor's compliance and data security?
Does your firm have a Written Information Security Plan (WISP) that specifically covers your offshore service provider?
How would you describe your onshore team's ability to delegate and manage an offshore team?
Do you have a signed contractual agreement with your offshore vendor covering confidentiality and data security?
Has your firm mapped which tasks are appropriate to offshore versus keep onshore?
Are you familiar with AICPA Code 1.700.040 — the disclosure rule for third-party service providers?
What is the size of your firm?
What is your primary goal right now?
Offshore Readiness Score
Sending to Your Inbox
Offshore Readiness Summary PDF (personalized)
Sample GOA Vendor Scorecard preview
§7216 Quick Reference Guide for CPA Firms
Book Outsourcing Advisory Bundle →

Full PDF report sent to your email within minutes

JD

Jason Dinesen

EA · LPA · GOA Founder & Lead Advisor

Nationally recognized CPE presenter and compliance authority who has trained 200,000+ accounting professionals on IRS guidance, ethics, and tax law. Now bringing that expertise to offshore advisory — helping CPA firms navigate the legal, compliance, and strategic complexity of building global teams.

200K+
Professionals trained on tax & ethics
500+
CPA firms advised on outsourcing
15+
Years in accounting & advisory
3
Core regulatory domains mastered
Enrolled Agent (EA) Licensed Public Accountant CPE Presenter — MYCPE ONE IRC §7216 Authority FTC Safeguards Expert GCC Advisory
About Jason

The Compliance Voice the Offshoring Conversation Was Missing

Most offshore advisory firms talk about cost and talent. Jason Dinesen talks about something most vendors won't raise: the legal and regulatory obligations that fall entirely on the CPA firm — regardless of which vendor they choose.

Known for breaking down complex tax law into plain, actionable language, Jason brings that same clarity to outsourcing compliance. Firms that work with Jason leave with specific documents in hand, a clear action list, and the confidence that they've handled this correctly.

  • 📜
    IRC §7216 & IRS Consent Requirements

    Deep expertise in consent structure, foreign disclosure rules, adequate data protection safeguard standards, and criminal/civil penalty exposure for tax return preparers.

  • 🏛️
    AICPA Professional Ethics

    Comprehensive knowledge of how Code rules 1.150.040, 1.700.001, and 1.700.040 apply specifically to offshore arrangements — with practical language firms can implement.

  • 🔒
    FTC Safeguards Rule

    Practical guidance on WISP requirements, service provider oversight under §314.4(f), and what the FTC actually expects from accounting firms that use offshore vendors.

  • 🌐
    Global Offshore & GCC Strategy

    Strategic advisory on vendor selection, captive GCC buildout, onshore-offshore org design, geography selection, and building accounting operations that scale globally.

Book a Session with Jason →

Don't Wait for a Violation
to Find the Gap

The penalty for one §7216 violation is up to $1,000 per return — and that's before civil liability. A session with Jason is $399. The math is straightforward.