Santos v. H & R Block, Inc., 997 F.3d 990 (9th Cir. 2021)
Santos v. H & R Block, Inc.
Did H & R Block, Inc. breach its duty to Santos by failing to inform him of the FATCA requirements, thereby causing him financial harm?
Under negligence principles and contractual obligations, tax service providers like H & R Block are required to exercise reasonable care, skill, and diligence in providing tax advice and preparation services.
The Ninth Circuit Court held that H & R Block did not breach its duty, affirming the district court's dismissal of Santos' claims. The court concluded that the responsibility ultimately lay with the tax filer to be aware of and comply with FATCA requirements.
Santos v. H & R Block, Inc. is significant for law students as it illustrates the limitations and expectations placed on tax service providers with international clients. This case demonstrates the courts' reluctance to extend a tax preparer's duties beyond reasonable care in the absence of specific contractual obligations. Moreover, it stresses the importance of taxpayers' self-awareness regarding international financial compliance, shaping the way tax-related advisory responsibilities are viewed.