I've got a new fairly complex client with foreign financial interests. He has a tax attorney in Switzerland that 'coordinates' these affairs.
I'm not comfortable with some of the arrangements that include foreign grantor trusts with non-us grantor. He needs to file a few of the IRS foreign informational forms. My discomfort is not because they appear illegal but because they are above any foreign financial affairs I've dealt with previously.
For Form 3520, I believe the Swiss firm can sign as a paid preparer. For the other forms ( 8938 and 5471) they are incorporated with the 1040, so it is essentially my signature on the form. As I mentioned, I don't have statements or the origin documents for some of the underlying assets --- all the info I have is coming direct from this Swiss law firm.
My question: Can I draft the engagement letter to insulate me from any bad information I receive on the preparation of 8938 and 5471, etc.?
Looking for advice. Thanks.