AI for Tax Season: Collecting Client Tax Documents

Every January, an advisory firm that gathers tax documents for clients chases the same forms from custodians, employers, lenders and partnerships, then sends them on to each client's CPA. AI helps with the clerical part: working out which forms to expect, recognizing what arrives, naming it, and keeping the list of what is still missing. The CPA decides the tax treatment. The planning conversation is a separate workflow, in AI for tax planning conversations.

The IRS dates below come from the instructions posted on irs.gov as of November 1, 2026. Check the current year's instructions when the IRS posts them.

Build each household's expected-forms list

Start in December, before anything arrives. Last year's package and the firm's account list show most of what to expect.

AI drafts the list from last year's index, the custodial account list and CRM notes. It flags accounts opened or closed during the year, a new employer mentioned in meeting notes, and a new partnership investment. A person confirms the list with the client in early January, because a client's outside bank account or second job will not be in the firm's systems.

A drafting prompt:

From last year's tax-document index, this year's account list and the CRM notes provided, list the tax forms this household should expect for 2026. For each, give the form, payer, account ending digits and why it is expected. Flag accounts opened or closed during 2026 and anything in the notes that is not on the account list. Do not include balances or amounts.

When forms arrive: IRS furnishing dates

The Guide to Information Returns in the IRS's General Instructions for Certain Information Returns (2025) gives these dates for furnishing forms to recipients:

• Form 1098, 1099-DIV, 1099-INT and 1099-R: January 31.
• Form 1099-B: February 15. The instructions say the February date "also applies to statements furnished as part of a consolidated reporting statement," so plan around it for any consolidated 1099 that includes a 1099-B.
• Form 5498: January 31 for fair market value, RMD and SIMPLE IRA contribution information, and May 31 for all other contributions.

Two forms come from other instructions. For W-2s, the 2026 instructions say employers generally must furnish employee copies "by February 1, 2027." For K-1s, the Form 1065 instructions say "Schedule K-1 must be provided to each partner on or before the day on which the partnership return is required to be filed." A calendar-year partnership's return is due March 15, and a partnership can request more time by filing Form 7004.

The IRS moves these dates when they fall on a weekend. For forms covering 2025, it set February 2, 2026 for most statements and February 17, 2026 for 1099-B and consolidated statements.

Three things follow for the calendar:

• Schedule the first custodial chase after the February date, not in January.
• Mark contribution 5498s "expected May" so nobody holds a CPA package waiting for one. Ask the CPA what they want in its place, such as the custodian's contribution confirmation.
• Give K-1s their own track. A partnership that requests more time with Form 7004 may send them later than March.

Collect through a portal, not email

Tax forms carry Social Security numbers and account numbers. The SEC's amended Regulation S-P applies to investment advisers registered with the Commission, and its safeguarding and disposal requirements cover all customer information. The SEC gives a Social Security number as an example of sensitive customer information. Larger entities had to comply by December 3, 2025 and smaller entities by June 3, 2026.

The amendments require an incident response program, notice to affected individuals "as soon as practicable, but not later than 30 days, after becoming aware" of unauthorized access, and oversight of service providers, including notice to the firm no later than 72 hours after a service provider learns of a breach of a system it maintains. Every portal, document tool and AI vendor in this workflow falls under that oversight.

In practice:

• Give each household one upload link in the firm's portal, and ask clients not to email forms. If a form arrives by email anyway, move it into the portal and follow the firm's policy for the email copy.
• Where the custodian makes clients' tax forms available to the firm, download them there instead of asking the client.
• Run AI only in a tool on business terms that the firm's vendor review has approved. NASAA's adviser guidance notes that even when AI programs take steps to protect data, "they do not guarantee complete confidentiality." The client data page sorts tools by what data each may hold.

Sort, name and log with AI

Each upload gets the same treatment. A model reads the file and returns the form type, tax year, payer, account ending digits, whether the CORRECTED box is checked, and a confidence rating for each field. The workflow renames the file to one pattern, such as 2026_Lastname_1099-Consolidated_Payer_1234.pdf, and adds a line to the household's index.

Keep the model's job to identifiers. Dollar amounts stay out of the index, and the CPA reads them from the forms.

The workflow then matches each file to the expected list and sorts it into received, missing or unexpected. An unexpected form, such as a 1099-INT from a bank nobody listed, goes to the advisor as a question for the client.

A classification prompt:

For each attached PDF, return: form type, tax year, payer name, recipient name, account ending digits, whether the CORRECTED box is checked, and a confidence rating for each field. If a page is unreadable or the form type is unclear, say so instead of guessing. Do not return dollar amounts.

The missing-items list

The match produces the list. Each line carries the household, form, payer, the IRS date it is due to the client, status, next step and the staff member who owns it. Refresh it after each batch of uploads and on a fixed day each week.

AI drafts the reminder to each client, naming only the outstanding forms and payers. No figures and no full account numbers go in the email. A person sends it.

For a missing W-2 or 1099-R, IRS Topic 154 sets the order: contact the employer or payer first, then call the IRS if the form still has not arrived "by the end of February." The IRS then contacts the employer or payer and mails Form 4852. Put those steps on the list as the client's next actions. Topic 154 also says that if a corrected form arrives after the return is filed and it differs, the taxpayer must file Form 1040-X. Log corrected forms and send each one to the CPA the day it arrives.

Hand the package to the CPA

Regulation S-P's exceptions to its notice and opt-out requirements include disclosures made "With the consent or at the direction of the consumer, provided that the consumer has not revoked the consent or direction." Record each client's direction to send documents to a named CPA before the first package goes out.

The package holds:

• An index listing form, payer, account ending digits, date received, and whether each form is an original or a correction.
• The outstanding list with each item's due date.
• The forms, delivered through the firm's portal or the CPA's, not as email attachments.

Send one package when the main forms are in, then dated updates as late forms and corrections arrive, so the CPA knows which version is current. Leave tax positions to the CPA. If the firm harvested losses during the year, the checks done before year-end are in tax-loss harvesting with AI tools.

What a person checks

• The expected list, confirmed with the client in January.
• Every file the model rated low confidence, plus a sample from each form type.
• That each corrected form replaces the original in the package, with the original kept in the file.
• That no reminder or cover email carries figures or full account numbers.
• That the client's direction to share with the CPA is on file before anything is sent.
• That every vendor touching the files, including the AI tool, has been through the firm's service provider review.
• That staff access to the portal is trimmed after the season.