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may not be withheld. It is critical to note guidance in thinking through the analy- practice, create a checklist to assist
that the member is not required to pro- sis. For instance, Question 1 addresses staff when documenting the services
vide the client with their working papers whether the electronic data file within a provided;
(subject to federal and state laws and member’s tax preparation software is a ■ Create a written record-retention
contractual agreements that may impose member-prepared record or a working plan, including specific record-
additional requirements). paper and concludes that it is a working retention periods; and
When applying these rules, the most paper. Just as important, the explanation ■ Set aside time in less busy periods to
challenging determination often is of why it is a working paper (even though annually review retained documents
whether a record is a member-prepared it contains tax data obtained from the for possible disposal. ■
record or a working paper. With the client’s records) provides a guideline to
prevalent use of tax preparation software help the tax practitioner work through Contributors
and other electronic tools, the dividing similar questions.
line between a member-prepared record Karen L. Jones, CPA, is director, One
and a working paper seems harder to Practices to consider Firm Risk Organization at Pricewater-
divine. The Electronic Records section The topic of documentation and houseCoopers LLP in Washington, D.C.
within the AICPA guidance Frequently recordkeeping for a tax practitioner Stephen P. Valenti, CPA, is professor
Asked Questions: General Ethics as can be quite complex. To help with the emeritus of accounting at New York Uni-
of March 18, 2022, may be helpful to application of these concepts, here are versity. Both are members of the AICPA
the member in determining whether some practices to consider: Tax Practice Responsibilities Committee.
a record is a member-prepared record ■ Determine the types of documenta- For more information about this column,
or a working paper. It addresses seven tion to be retained; contact thetaxadviser@aicpa.org.
common questions that provide useful ■ Depending on the size of the

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