APS Guidelines A CPA providing tax services may register as another type of agent with the IRS, such as an enrolled agent, paid tax preparer, etc. to be able to provide tax services within the APS/non-CPA firm. In this case, the CPA cannot hold out, offer, or provide CPA professional services within the APS/ non-CPA firm, but can sign the tax returns as their designated agent with the IRS (EA, paid tax preparer). ACPA licensed as a sole proprietor or as a licensed CPA firm may hold out, offer, and provide professional services within an APS (a non-CPA firm) with the following guidance: • Any engagement letters provided to clients should clarify the professional CPA services are being provided by the CPA under their sole proprietorship or CPA firm. • Within any advertising, including website design by the non-CPA firm, it must be clear the CPA provides professional CPAserviceswithin their sole proprietorship or CPA firm. • CPAs can use the non-CPA firm’s letterhead, business cards, etc., however would need to state somewhere that professional CPA services are being provided through the sole proprietorship or CPA firm. As one example, this could be through a disclaimer or asterisk under the CPA’s name. CPAs working within an APS may sign off on experience hours earned by the staff they supervise. Per PAA 1-136.02(1) (a) and (b), the necessary experience requirement for initial licensure will depend on who employs the CPA supervisor and staff member. • If the licensed sole proprietorship or CPA firm employs both, the experience requirement will be at least 4,000 hours earned in at least 2 years. • I f the APS (non-CPA f i rm) employs both, the experience requirement will be at least 6,000 hours in at least 3 years. • If the staff member is employed by the APS (non-CPA firm), the CPA supervisor must also be employed by the APS to be able to sign off on the experience hours earned. The Nebraska Board of Public Accountancy administers public accountancy law in Nebraska. Dan Sweetwood is executive director of the Nebraska Board of Public Accountancy. You may contact him at (402) 471-3595 or dan.sweetwood@nebraska.gov. You may also contact State Board Administrator Kristen VanWinkle at kristen.vanwinkle@nebraska.gov or State Board BusinessManagerHeatherMyersatheather.myers@nebraska.gov. HBE LLP is pleased to announce that for the eighth consecutive year, they have been named to the Accounting MOVE Project’s 2022 Best Firms for Equity Leadership and 2022 Best Firms for Women. With women leading 42% of the firm, HBE is one of the 15 firms awarded with these honors nationwide. The MOVE methodology investigates the factors proven to be essential for career success: Money, Opportunity, Vital supports, and Entrepreneurship. HBE emphasizes employment programs proven to retain midcareer women, including phased return to work for new parents, remote-work opportunities, worklife supports for the busy season, and coaching to help managers lead teams based on productivity, not face time. “We are committed to fostering an environment where all of our associates, regardless of gender, age, race, or other diversity, are able to thrive within the profession,” stated Scott Becker, Managing Partner of HBE. “Through our core values centered on integrity, respect, and teamwork, we will continue to support and advance flexible leadership pathways built upon unique contributions and talents.” www. hbecpa.com 11 nebraska society of cpas W W W . N E S C P A . O R G
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