Adding a Retirement Conversation to Every 1099 Engagement Without Becoming an Adviser

The gap in most 1099 engagements

A preparer finishes a Schedule C, computes self-employment tax, and files. The client leaves with a bill and no idea that a $12,000 to $50,000 deduction was available. The reason is rarely ignorance. It is that the preparer is not sure how far into "retirement" they can go without stepping into territory that requires a different licence.

The line is clearer than most practitioners assume, and it leaves room for a substantial, standardized conversation on every 1099 return. This article draws the line, provides the standard step, and explains how the Gigaverse CPA program sits on the tax side of it.

Where the line actually is

The Investment Advisers Act defines an investment adviser as a person who, for compensation, engages in the business of advising others about securities. Three elements: compensation, business, securities. The accountant exclusion in Section 202(a)(11)(B) removes accountants whose advice is solely incidental to their accounting practice.

What that leaves on the tax side:

• •Contribution limits. How much a client can put into a Roth IRA ($7,500 for 2026), a SEP (roughly 20 percent of adjusted net self-employment earnings), or a Solo 401(k) ($24,500 deferral plus the employer piece, up to $72,000 or $80,000 at 50 and older) is arithmetic on the return.
• •Account type. Whether a Solo 401(k) or SEP produces the better tax result for this client is tax advice. Whether a pre-tax or Roth deferral is preferable given the client's bracket is tax advice.
• •Deadlines. December 31 for the Solo 401(k) deferral election; the extended due date for SEP adoption and funding; April 15 for the Roth IRA.
• •Eligibility. Whether the client's income allows a Roth IRA, or falls within the Saver's Match phase-outs starting January 1, 2027.
• •Where a payment lands. For example, that the Saver's Match must be paid into a non-Roth IRA even when the qualifying contribution was Roth, which Gigaverse explains on its Saver's Match Roth rule page.

What crosses the line:

• •Recommending specific securities or funds to hold inside the account.
• •Constructing or managing a portfolio.
• •Being compensated by the client, or by anyone else, for advice about securities.
• •Holding yourself out as offering investment advice.

The safe formulation for a client: "I can tell you how much you can contribute, into which type of account, and by when. I cannot tell you what to invest in inside it. For that you need an adviser, or a product that handles it under its own registration."

The standard step

Add one section to every Schedule C engagement, in the workpapers and in the client deliverable.

Step one: compute the room. Net profit, less half of SE tax, times 20 percent for the employer piece. Note the $24,500 deferral if a Solo 401(k) is in place or could be. Note the $7,500 Roth IRA limit and whether income allows it. For drivers, confirm the 2026 mileage split of $0.725 per mile January through June and $0.76 July through December, because it changes the base.

Step two: state the tax effect. Marginal rate times deductible contribution. For a client at 22 percent with $17,000 of SEP room, about $3,700.

Step three: state the deadline and the account-type consequence. "You can still fund a SEP for last year by October 15 if we extend. For this year, a Solo 401(k) would let you put in about $24,500 more, but the election must be signed by December 31."

Step four: hand off the execution. Point the client to a tool that tracks contributions and deadlines through the year and returns the numbers to you at filing time, and to an adviser or a product for the investment side.

Four steps, five minutes, zero investment advice.

Compensation, and the two rules that govern it

If your firm is compensated for the hand-off in step four, two bodies of rules apply, and both are manageable.

AICPA ET §1.520. A member in public practice may not accept a commission or referral fee for recommending a product or service to a client for whom the firm performs attest services, during the period of the attest engagement. For all other clients, any commission or referral fee must be disclosed to the client, and most state boards require the disclosure in writing before or at the time of the recommendation. A share of subscription revenue is a commission for this purpose.

Securities law on the form of payment. Compensation tied to a client opening an account or depositing money resembles transaction-based compensation under Exchange Act Section 15(a) and FINRA Rule 2040, which is broker-dealer territory. A share of advisory fees would violate the rule that an SEC-registered adviser cannot share fees with unregistered parties. Paid solicitation of advisory clients can trigger state investment adviser representative registration. And SEC Marketing Rule 206(4)-1 requires the adviser to have a written agreement with, and deliver a disclosure about, any compensated promoter above $1,000 in twelve months.

Gigaverse, which is pursuing SEC RIA registration, addresses every item by paying CPAs only a share of revenue on paid app subscriptions or a flat per-seat licence, never per account, per deposit, or on assets. It supplies the §1.520 disclosure text and the Marketing Rule agreement. The client-facing version is the how we make money page.

Scaling it across a practice

• •Engagement letter. Add the retirement step to the scope and the §1.520 disclosure to the standard 1099 letter.
• •Workpaper template. A one-page contribution-room schedule per Schedule C client, computed from the return.
• •Attest flag. A client-record field that suppresses the referral for any client with an open attest engagement.
• •Fall touchpoint. A November email to every Solo 401(k) candidate about the December 31 election. This single touch captures more deduction than any other step in the year.
• •Client tools. The free Gigaverse tools let a client reproduce your contribution-room schedule from their own estimate, which is useful for mid-year check-ins.

The market you are already serving

MBO Partners counted 72.9 million independents in 2025, with 11.5 million providing independent professional services (https://www.mbopartners.com/blog/press/2025-state-of-independence-reveals-growing-talent-strategy-for-business). Only 15 to 18 percent of self-employed people use a Solo 401(k) (https://www.solo401k.com/blog/solo401k-adoption-growth-statistics-usa). The practitioners who close that gap will not be advisers. They will be preparers who added a five-minute step to a return they were already filing.

Where Gigaverse fits

Gigaverse is a subscription retirement app for people with 1099 income. Today it offers a Roth IRA through a FINRA/SIPC-member broker-dealer; and applications for a Solo 401(k) and a SEP IRA are open at gigaverse.ai/solo-401k and gigaverse.ai/sep-ira, reviewed by a person rather than opened instantly in the app. It also computes the limits, tracks contributions and deadlines through the year, and returns a summary to the preparer at filing time. It is pursuing SEC RIA registration and does not guarantee returns. CPA partners are paid only a share of subscription revenue or a flat per-seat licence and receive a §1.520-ready disclosure. Program details are on the CPA partner page.