Who this is for
- Owners of a sole proprietorship, partnership or corporation whose books are months or years behind
- Owners comparing online and local providers before they sign a scope or pay a deposit
- Owners whose returns, payroll or sales tax filings depend on the overdue books
Not covered here
- What catch-up costs and what drives a quote
- Whether to keep the books yourself or hire at all
- Preparing the late returns themselves
- Ranking or recommending a named provider
- Canadian bookkeeping and accountants
What should a catch-up or cleanup bookkeeping service hand back when the job is finished?
A finished catch-up job gives you books in which every account is reconciled to its statements for every month in scope, the totals agree with what you already filed or each difference is listed, and you hold the file. A job that only sorted transactions is nearly done, not done. Reconciled means the books' balance for an account at each month-end equals the statement balance, with every difference explained.
| Check | Finished | Nearly done |
|---|---|---|
| Accounts | Every bank, card, loan and payment account is reconciled to its statement balance, month by month (Publication 583 covers the monthly checking-account reconciliation) | Transactions are categorized, but balances were never matched to statements |
| Filed returns | Totals agree with each filed return (a sole proprietor's with Schedule C), or each difference is listed. Where a partnership or S corporation must complete Schedule L, its balance sheets should agree with its books (Form 1065; Form 1120-S) | The books start from a guess |
| Income | Sales are compared with Forms 1099-K and 1099-NEC, and deposits that match nothing are listed. Form 1099-K shows gross amounts, before fees, refunds and shipping (instructions). A marketplace or payment app must file one only when payments exceed $20,000 in more than 200 transactions (some file below that), so sales without a form are still income (IRS) | Deposits are booked as sales |
| Payroll and sales tax | The books are compared with returns filed and payments made | Taxes are booked but never compared with filings |
| Open items | A dated list of what could not be classified and what would settle each item | Guesses sit in a catch-all account |
| Handover | A file backup, the reconciliation reports and the open-items list, with you as administrator | A PDF of reports |
Some differences are normal: a partnership or S corporation that completes Schedule M-1 or M-3 reconciles income per books with income per return there, because tax rules change what a return reports, for example for some meal expenses (Form 1065; Form 1120-S). A difference that tax rules do not explain may mean the filed return was wrong. Ask the provider to list it, not to force the books to match; whether to amend is a question for a CPA, enrolled agent or attorney.
This page is for you if your books are months or years behind, a return or lender date is coming, and a do-it-yourself try or an earlier bookkeeper stalled. Three points are then open: which months and accounts the work covers, who prepares the returns that depend on the books, and the order of work. A case is not simple when returns are also unfiled, an IRS notice has arrived, or payroll or sales tax filings are missing. Those cases need someone who can prepare returns and speak to the IRS (covered below), and a notice, an audit or years of unfiled returns come first (see "When is a catch-up service the wrong first step?"). Gather what you need before asking for quotes (list at the end). For the steps of getting books tax-ready, see catching up on overdue books.
Does the person catching up my books need to be a CPA?
Generally no, as far as the IRS is concerned. The IRS credential list covers preparing returns and representing taxpayers, not bookkeeping, so for the books themselves fit matters more than a title (IRS credentials). State rules on who may offer accounting services are not covered here; see local or online bookkeeper. Credentials start to matter when the work touches a return or the IRS.
| Job | Who the IRS recognizes | How to check |
|---|---|---|
| Keep or rebuild the books | No IRS credential applies | A sample of finished work, references and a trial month |
| Prepare a return for pay | Anyone with a PTIN, who signs the return and enters the PTIN on it (PTIN rules; Topic 254) | The signature and PTIN on the return |
| Represent you before the IRS | CPAs, enrolled agents (licensed by the IRS) and attorneys in any matter, including audits, collection and appeals. Annual Filing Season Program holders only in an examination of returns they prepared and signed, with a record of completion for both the return year and the examination year (Publication 947). A PTIN alone gives no right to represent | The credential and its number (see below) |
An outside provider with none of those credentials generally cannot represent you in collection or an appeal, however good the books are (Publication 947). For more on the difference, see bookkeeper, accountant or CPA.
My returns are behind too: who can prepare them and speak to the IRS for me?
Whoever prepares and signs each late return needs a PTIN, and only a CPA, enrolled agent or attorney can represent you in every kind of IRS matter. Two providers can share the job if the scope says who does what.
- Preparing and representing are separate. The paid preparer signs the return, yet you remain accountable for every item on it (Topic 254). A power of attorney on Form 2848 names individuals, because firms cannot practice before the IRS (Publication 947).
- Information only. Form 8821 lets a named person see or receive your IRS information but not speak for you (Form 8821 instructions).
The written scope should name who prepares each late return, who signs and files it, and who holds the Form 2848 if a notice or audit follows. Form 2848 covers the IRS only, and a partnership under the centralized audit regime (the default unless it elected out) acts through its partnership representative, who signs it (instructions). State agencies set their own rules on who may speak for you on sales tax, state payroll or state income tax, which this page does not cover; name in the scope who handles those filings. Late returns themselves are covered in catching up on unfiled business returns.
How do I check a provider's credentials, online or local?
The checks are the same online or local: get the name of the individual who will do the work, the credential and its number, and confirm it with the body that issued it. For practice before the IRS, location does not matter, because a CPA qualified in any state may practice before it (Circular 230, sections 10.2 and 10.3). State licensing, payroll and sales tax rules can differ and are not covered here.
- Name the individual. Ask who will prepare, sign and represent, not just the firm's name.
- Check the credential at its source. The IRS licenses enrolled agents, state boards of accountancy license CPAs, and state courts or bars admit attorneys (IRS credentials). Ask for the state and license number and confirm it with that body.
- Use the IRS directory as one check. It lists attorneys, CPAs, enrolled agents and Annual Filing Season Program holders, and is linked from choosing a tax professional. Preparers with a PTIN who are not listed may still provide quality service, so a missing name is a question to ask, not proof of a problem.
- Ask who will answer questions after filing (Topic 254).
No official source ranks providers, and a review cannot replace a credential you verified yourself. Test any provider, online or local, with one batch first, as the written scope below sets out. For fit and software, see local or online bookkeeper; for a provider in another country, see hiring an offshore bookkeeper.
Who owns the books and the files when the job ends?
Who owns a finished ledger depends on your agreement and state law, but the tax system makes the taxpayer responsible for keeping sufficient books and records, and in many examinations the IRS asks for the accounting-software backup file and the administrator's username and password (IRS software FAQ). Create the file in the business's name, stay administrator, and give the provider a named user.
- Keep the original entries. Ask the provider to fix errors with dated correcting entries, not by deleting entries or building a replacement file, and to archive a copy before large changes. The IRS says a new file created for an examination, for example by re-entering one year, is not a copy of the books of original entry, and condensed data is not acceptable for a year under audit (same FAQ).
- Returning records is a rule for practitioners, and its reach here is unclear. A practitioner, such as a CPA, enrolled agent or attorney, must promptly return, on request, the client's records the client needs for federal tax obligations (Circular 230, section 10.28). A fee dispute generally does not excuse returning them; where state law lets a practitioner keep records during one, the practitioner need only return those that must be attached to your return, and must let you review and copy the rest. A document the practitioner prepared and is withholding until its fee is paid is not a client record under the rule (same section). The rule ties client records to the practitioner's representation of the client and does not say whether bookkeeping alone counts. A provider who is not a practitioner is not covered, and state law may add rules this page does not review. If a provider already holds your file, see taking over books from a former accountant.
Because a finished ledger can be held back, write the handover into the scope and keep administrator access from day one. At the end, collect a full backup, the reconciliation reports, the open-items list and your originals, and remove the provider's access. The IRS tells tax professionals to remove authorizations for people who are no longer clients (Publication 4557). To revoke one, write "REVOKE" across the top with a current signature and date, and send a copy to the IRS (Form 8821 instructions; Form 2848 instructions).
What do I give a provider, and what should I avoid handing over?
Give a provider what the work needs and nothing that lets them move money, receive your refund or act for you without a record. Give each person a login of their own.
| Subject | Give | Avoid |
|---|---|---|
| Bank and card accounts | Statements, and a separate login with the narrowest access that works | A shared login in your own name, or access that can move money (see giving a bookkeeper access) |
| IRS information and representation | A Form 8821 naming the taxes, forms and years the work needs, or a Form 2848 for a named, credentialed individual if representation is in scope (instructions) | Your own IRS sign-in, since the forms authorize the provider in their own name. A form that outlives the job. A new Form 8821 revokes your earlier Forms 8821, and a new Form 2848 revokes earlier ones for the same matters and years, so a form given to another preparer can end unless you check the retention box and attach a copy to keep (Form 8821; Form 2848) |
| Refunds and payments | Payment from your own account | Any arrangement that sends a refund to the provider's account. A representative may not negotiate a government check, and the IRS lists diverting a refund as misconduct (Form 2848 instructions; IRS) |
| Signatures | Your signature on a completed form | A signature on a blank form (Topic 254) |
How is my financial data protected, and what should I ask?
Ask for the provider's written security plan. The FTC Safeguards Rule requires tax return preparers to create and follow one (Publication 4557). Whether it reaches a given bookkeeper depends on what the provider does, so use Publication 4557 as a yardstick for anyone who holds your bank and tax data, not as a rule that binds every bookkeeper. Ask:
- Who runs the written security plan?
- Does everyone who reaches my data sign in with more than a password?
- Are files and emails encrypted?
- Who can see my data, and which other companies handle it?
- What happens to my data when we finish, or if it is lost?
Publication 4557 asks tax professionals for each of these. A plain, specific answer is a better sign than a general promise. For a bookkeeping-and-tax bundle compared with a CPA firm, see online bookkeeping service or CPA firm.
If the provider is late or wrong, am I still responsible to the IRS?
Generally yes. Hiring a provider does not move your duty to file, pay and keep records, and the IRS says reliance on a tax professional generally does not excuse a late filing or payment (IRS reasonable cause). Relief depends on the facts of each case. Inability to get records is among the IRS's examples of a valid reason, but only for someone who used ordinary care and prudence and still could not file or pay on time (same page).
- Accuracy penalties: the IRS looks at whether you gave your advisor all the information needed and whether the advisor was competent and experienced in the situation (same page).
- Payroll: an employer that outsources payroll generally remains responsible for deposits and filings, and the IRS may assess penalties and interest on the employer's account. Publication 15 names one exception, a certified professional employer organization (Publication 15).
Keep control: put filing and payment dates in the scope, ask for proof that each return or payment went out (reasonable-cause page above), and check your IRS accounts yourself: a Business Tax Account (IRS) or your individual online account (IRS) shows balances, transcripts and notices, and who can use a Business Tax Account depends on entity type and role. For payroll, see giving a bookkeeper access to your accounts. If a penalty has already arrived, see bookkeeper mistakes and who pays the penalties.
What should the written scope say before I pay?
The scope should let a stranger tell whether the job is done. Write down these points before any deposit:
- Period and accounts. The first and last month, and every account by name and last four digits: bank, card, loan, payment processor, marketplace and payroll.
- Deliverables. For each month, reconciled statements for every account, plus a profit and loss and a balance sheet.
- Agreement with filed returns. Opening balances (what each account held on the first day in scope) come from the last filed balance sheet or, if the return has none, the year-end statements. Each filed year agrees with its return or the differences are listed, and income is compared with Forms 1099 and platform payout reports.
- Payroll and sales tax. The books are compared with returns filed and payments made, and the scope says whether late filings are included.
- Returns. For each return that depends on the books: who prepares it, who signs and files it, who holds a Form 2848 if representation is included, and what is excluded, such as notices, audits or amended returns.
- Order and dates. Which period is finished first (the one a return or lender needs), a finish date for each batch, and what would move it. Treat the first batch as a test: check it against the statements before the next batch starts or the next payment is due.
- Open questions. The provider keeps a dated list of what it cannot classify and what would settle each item. You answer by an agreed date, and items still open at the end are listed, not guessed.
- Ownership and access. The file is in your name, you are administrator, the provider is a named user, and the scope lists what is returned at the end.
- Price basis. Fixed, hourly or monthly, and what triggers more: extra accounts, missing statements or changes after sign-off. The drivers are in catch-up bookkeeping cost.
For contract terms, see bookkeeping engagement letter; for what to ask before hiring and how to check the first batch, see questions to ask before hiring a bookkeeper and checking your bookkeeper's work; for what a service should deliver once the books are current, see what a monthly bookkeeping service includes.
When is a catch-up service the wrong first step?
When a deadline or enforcement step, not the books, sets the order of work. In each case below, deal with that step first, with someone who can represent you if it calls for one, and let the books follow.
| Situation | What the IRS says | Start with |
|---|---|---|
| A notice with a response date | If the IRS asks you to respond, act by the due date, and reply by it to protect appeal rights (IRS) | Read the notice and note the date. See IRS notice to your business |
| Several years of unfiled returns | File all past-due returns whether or not you can pay. The IRS may file a substitute return that might not credit your deductions (IRS). No time limit applies to assessing tax on a return never filed (Publication 583). A late partnership or S corporation return draws a penalty for each partner or shareholder for each month late, up to 12 months, even when no tax is due (Form 1065; Form 1120-S) | A plan for the returns, then books rebuilt in the order the returns need. See catching up on unfiled business returns; for penalty rates and relief, see late business return penalties |
| An examination (audit) | The IRS usually asks for the original software file when the books are kept in software, and a file made for the audit does not meet the request (IRS software FAQ) | A credentialed representative before anyone changes, rebuilds or purges the file |
| Withheld payroll tax not paid | A responsible person who willfully fails to pay can be charged personally (section 6672) a penalty equal to the full unpaid withheld income tax and employee Social Security and Medicare tax. That can include people in your own business when a payroll provider made the deposits. A proposed-assessment letter allows 60 days to appeal (IRS). The IRS generally has 3 years from the later of the April 15 after the payroll year and the date the return was filed to assess it, and no limit runs until a payroll return is filed (IRS staff manual) | A credentialed representative. The person charged needs their own Form 2848 that names the penalty (instructions). Check your IRS employment tax account |
A lender or sale date does not make catch-up the wrong step. It sets the order: ask what periods the lender or buyer will want, and put those first. Loans can be delayed when returns are missing (IRS). If you have only bank statements and no books, see rebuilding books from bank statements.
What do I gather so the quote and the timeline are real?
Gather statements for every account for every month, filed returns, payroll and sales tax reports, and Forms 1099: a provider can only quote what they can see, and each missing item adds time. The IRS lists account statements, invoices, receipts and canceled checks among the supporting documents behind your books (Publication 583). Bring:
| Item | Why it matters | If it is missing |
|---|---|---|
| Statements for every bank, card, loan and payment account, every month | Reconciliation needs the statement balances | Ask each institution for copies and list any gap |
| The filed returns for the years in scope, and the last one before them | They set the tie-out and, where a balance sheet was filed, the opening balances | Get transcripts from your IRS online account, or from a Business Tax Account for a business return (IRS; IRS) |
| Payroll returns and reports | They check the payroll lines. Employment tax records must be kept at least four years (Publication 583) | Ask the payroll provider, and view your IRS employment tax account |
| Sales tax returns and account numbers | They check the sales tax lines | Request them from the state tax agency |
| Forms 1099-K and 1099-NEC, and payout reports from every platform | They test the income | Download the reports from each platform, then request a wage and income transcript with Form 4506-T (IRS) |
| Loan papers, leases and invoices for major purchases; the prior bookkeeper's file or last backup | They support balances and depreciation, and show past treatment | List what is missing |
Add a short note of which accounts or cards are personal, what you know of money you put in or took out, and anything you know is missing. Keep every original.
Example
These examples are illustrative and use US dollars.
Restaurant, 18 months behind
A restaurant owner with US$600,000 of revenue is 18 months behind across four accounts: an operating account, a payroll account and two cards. Before agreeing to a price, the owner asks for a monthly bank and card reconciliation for each account, a reconciliation of sales tax from the register reports to the return (see restaurant sales tax and POS reconciliation), and a close date for each batch, with the months a lender will ask for first. The owner stays administrator of the accounting file throughout.
S corporation, two returns also unfiled
An S corporation owner is two years behind on the books, and the Form 1120-S for both years was never filed. Assume the S election is in effect. A scope for bookkeeping alone covers neither the returns nor a letter if one arrives, and each late return can carry a monthly penalty for every shareholder whether or not tax is due. So the scope names who prepares and files each return, who signs, and which CPA, enrolled agent or attorney holds the Form 2848.
- Year 1: reconcile every account, set opening balances from the last filed balance sheet or the year-end statements, and finish Year 1 first, because its return needs it.
- Year 2: continue from Year 1's closing balances, then prepare the Year 2 return.
Online seller, payouts that do not match the Form 1099-K
An online seller made US$80,000 of sales through two marketplaces. Assume each marketplace passed the Form 1099-K reporting threshold and no shipping or sales tax is in the forms. The two Forms 1099-K add up to US$80,000, the gross amount. The deposits total US$73,000. Sales less US$7,200 of fees and US$1,800 of refunds explain US$71,000 of them, and US$2,000 matches no sale. Before agreeing to a price, the seller asks what the provider does with a deposit that matches no sale. The scope then says each payout is tied from gross sales through fees and refunds to the deposit, and unmatched deposits go on the open-items list instead of into sales. See reconciling sales and payouts.
Different for you?
- Your books are months or years behind, a return or lender date is near, and a do-it-yourself try or an earlier bookkeeper stalled: the open points are which months and accounts the work covers, who prepares the returns that depend on the books, and the order of work. These are the points to settle before you sign a scope; see bookkeeping help.
- Returns for earlier years were never filed: see catching up on unfiled business returns. For the books those returns need, see bookkeeping help; for the returns themselves, see corporate tax help or, for a sole proprietor, individual tax help.
- An IRS notice or an audit letter has arrived: see IRS notice to your business. A CPA, enrolled agent or attorney can represent you on a notice or in an audit, so changes to the files are a question to put to one first.
- A provider's mistake has already led to penalties, or payroll tax was withheld but not paid: see bookkeeper mistakes and who pays the penalties.
- You are still deciding whether to hire, clean up the old file or start fresh, or what a quote should cover: see doing your own books or hiring a bookkeeper, cleaning up or starting fresh and catch-up bookkeeping cost.
- Your S corporation paid personal costs or large owner payments, you file a Schedule C, or you own rentals: see S corporation catch-up books, Schedule C expenses for unfiled years and catching up on rental property books.
- You or your company are in two countries, or you want a provider who works in Chinese: see books for a US LLC owned by a Canadian, bookkeeping for a foreign-owned US company and Chinese-speaking bookkeeper and accountant.
- Your books and filings are Canadian: see catching up on overdue books in Canada and choosing an accountant in Canada.
Figures on this page
| Figure | Value | Source |
|---|---|---|
| Federal Form 1099-K marketplace payment threshold Marketplace or payment-app payments must exceed this amount and exceed 200 transactions before federal third-party network reporting is required; payment-card transactions have no such threshold. | $20,000 | IRS: Understanding your Form 1099-K Checked |
| Maximum months for the section 6698 late partnership return penalty Each month or fraction of a month during which failure continues; reasonable cause and administrative relief may apply. | 12 months | US Code: section 6698(a) Checked |
| Trust Fund Recovery Penalty amount IRC 6672 penalty covers the trust-fund portion, not employer Social Security and Medicare contributions or FUTA | The full unpaid withheld income tax and employee Social Security and Medicare tax | IRS: Employment taxes and the Trust Fund Recovery Penalty Checked |
| Deadline to appeal a proposed trust fund recovery penalty From the date of the proposed assessment letter when addressed within the United States | 60 days | IRS: Employment taxes and the Trust Fund Recovery Penalty Checked |
| General trust fund recovery penalty assessment period From the succeeding April 15 for timely employment tax returns, or actual later filing; exceptions apply | 3 years | IRS: Trust fund recovery penalty assessment period Checked |
| US employment tax record retention Minimum, counted from the date the tax becomes due or is paid, whichever is later | Four years | IRS: Publication 583, Starting a Business and Keeping Records Checked |
Primary sources
- IRS: Choosing a tax professional
- IRS: Understanding tax return preparer credentials and qualifications
- IRS: Topic no. 254, How to choose a tax return preparer
- IRS: PTIN requirements for tax return preparers
- IRS: Publication 947, Practice Before the IRS and Power of Attorney
- IRS: Instructions for Form 8821
- IRS: Instructions for Form 2848
- IRS: Treasury Department Circular No. 230
- IRS: Tax return preparer misconduct
- IRS: Publication 4557, Safeguarding Taxpayer Data
- IRS: Publication 583, Starting a Business and Keeping Records
- IRS: Use of electronic accounting software records, frequently asked questions and answers
- IRS: Business tax account
- IRS: Your online account
- IRS: Penalty relief due to reasonable cause
- IRS: Publication 15, Employer's Tax Guide
- IRS: Employment taxes and the trust fund recovery penalty
- IRS: Internal Revenue Manual 5.7.3, Establishing Responsibility and Willfulness for the Trust Fund Recovery Penalty
- US Code: section 6672, Failure to collect and pay over tax
- IRS: Filing past due tax returns
- IRS: If you receive an IRS notice or letter
- IRS: Instructions for Form 1099-K
- IRS: Understanding your Form 1099-K
- IRS: Instructions for Form 1065
- IRS: Instructions for Form 1120-S
About this guide
Published by Cloud Accounting under standing professional approval. This version has no separately recorded personal review. It explains general rules for the tax year shown. It is not advice for your situation.
Changes
- : First published.