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standards where a lower or no standard members who already are aware of possesses the necessary competence
otherwise exists. and abide by Circular 230 and the to practice. Based on the discussions,
SSTS 4 does generally follow AICPA Code. It is recommended that members agreed that quality is a key
familiar concepts for experienced members read through and familiarize market differentiator in their practices;
tax practitioners. First, members can themselves with the new standard, however, its implementation is incon-
represent taxpayers in an issue they do identify any parts of their practice to sistent, and the environment in which
not have direct experience with, but which the standard is relevant, and members operate is dynamic.
they are expected to take steps to obtain ensure current practice is in line with Therefore, the AICPA is inviting
technical competence as part of that the new standard. members and stakeholders to comment
representation engagement. Second, on the questions raised in an Invitation
members are expected to comply with Invitation to comment to Comment. The task force and the
all other relevant professional and One of the aims of the AICPA Code is TEC will consider all comments in de-
regulatory obligations in providing to protect the public interest. Paragraph termining the best approach to address
representation services, such as Circular .01 of “The Public Interest” interpreta- quality within the tax function.
230 and the AICPA Code of Professional tion (ET §0.300.030) states: “Members
Conduct (the AICPA Code). Third, should accept the obligation to act in a Comments
members are expected to maintain way that will serve the public interest, As this is the first major update to
integrity and professionalism in dealing honor the public trust, and demonstrate the SSTSs in more than 10 years, the
with tax authority representatives. a commitment to professionalism.” AICPA realizes many members will
Fourth, members are expected to, with Members are expected to provide have questions and concerns. For this
taxpayer approval, respond timely to quality services in a manner that dem- reason, the standards are being exposed
tax authority requests for information. onstrates a level of professionalism for an extended period through Dec.
Fifth, members are advised to refer consistent with those goals. 31, 2022, to allow as many comments
any situations in which there may As part of the process to update the and questions as possible to be addressed.
be fraudulent or criminal taxpayer SSTSs, the task force held extensive Please send any comments and questions
activity to legal counsel and withdraw discussions around the importance of on the revisions to the SSTSs and the
from further representation. And additional concepts with the potential Invitation to Comment using our online
sixth, members are expected to review to significantly impact the tax practice form. Alternatively, members may email
documents or computations from an of the future. A resonating theme their submission to SSTScomments@
examination for correctness, discussing emerged in many discussions related aicpa-cima.com. All comments received
the results with the taxpayer. to quality management in tax, defined will be considered. Thank you for your
Application of this standard will as a proactive, risk-based, scalable ap- attention to this important change for
generally require little action for most proach to ensure that an individual firm tax practitioners. ■

SSTS Revision Task Force members Contributors

■ David J. Holets (chair), Crowe LLP, Indianapolis David J. Holets, CPA, is a partner and
■ Lea A. Fletcher, KPMG LLP, Charlotte, N.C. leader of tax quality control functions at
■ Nicholas M. Preusch, YHB CPAs & Consultants, Fredericksburg, Va. Crowe LLP in Indianapolis. Stephen P.
Valenti, CPA, is professor emeritus of
■ Thomas J. Purcell III, Creighton University, Omaha, Neb.
accounting at New York University. Mr.
■ Heidi A. Ridgeway, Grant Thornton LLP, Chicago Holets is chair of the AICPA Tax Practice
■ Stephanie S. Saunders, Saunders & Saunders PC, Virginia Beach, Va. Responsibilities Committee and the
■ Gerard H. Schreiber Jr., Schreiber & Schreiber CPAs, Metairie, La. SSTS Revision Tax Force, and Mr. Valenti
■ Norma J. Schrock, Ernst & Young LLP, Washington, D.C. is a member of the AICPA Tax Practice
Responsibilities Committee. For more
■ Joseph J. Tapajna, University of Notre Dame, Notre Dame, Ind. information on this column, contact
■ Christopher J. Wittich, Boyum Barenscheer PLLP, Bloomington, Minn. thetaxadviser@aicpa.org.
■ Henry J. Grzes (staff liaison), AICPA, Durham, N.C.

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