Proposed revisions to the AICPA tax standards

By Susan C. Allen, CPA/CITP, CGMA

The AICPA released proposed revisions to the Statements on Standards for Tax Services (SSTSs) for public comment on Monday. The combined document includes revisions to the existing standards, three new standards, and an invitation to comment on the subject of quality management in tax.

The SSTSs are the enforceable tax ethical standards that CPAs abide by and apply to all members providing tax services regardless of the jurisdictions in which they practice. Many state boards of accountancy also incorporate the SSTSs as part of their professional rules of conduct for CPAs.

Standards are the foundation of a profession. The AICPA aids its members in fulfilling their ethical responsibilities by instituting and maintaining standards in which their professional performance can be magnified. Compliance with professional standards of tax practice also reaffirms the public's awareness of the professionalism that is associated with CPAs as well as the AICPA.

Jan F. Lewis, chair of the AICPA Tax Executive Committee (TEC), stated, "Revising the standards is a powerful step forward to enhancing services provided by AICPA members so that they continue to be perceived as the premier providers of tax services."

Revisions to the SSTSs and more research and feedback needed

In September 2018, the TEC approved the formation of the SSTS Revision Task Force to update the SSTSs to (1) better reflect the issues and needs of members and the tax practices of today and in the future and (2) ensure the highest ethical standards for members to support the public's view that CPAs are the premier providers of tax services.

As part of those efforts, the task force:

  • Developed a new structure to organize the SSTSs by type of tax work performed;
  • Updated the existing standards to better reflect the current state of the tax profession; and
  • Drafted three new standards surrounding data protection, reliance on tools, and the representation of clients before taxing authorities.

In addition, the task force explored items that will require additional research and investigation to determine what, if any, revisions to the SSTSs should be made to address issues of quality management in tax.

Exposure Draft and Invitation to Comment

In releasing this combined Exposure Draft (ED) and Invitation to Comment (ITC), the AICPA presents the findings and conclusions of the SSTS Revision Task Force as approved by the TEC. The document is divided into two sections: Part 1: ED and Part 2: ITC.

The ED presents changes the AICPA proposes to make to the SSTSs. Following consideration of comments received, the changes outlined in the ED, if adopted, are expected to be included in a revised SSTSs document to be approved no later than May 31, 2023, and effective Jan. 1, 2024.

The ITC presents an item for consideration that will require additional research and investigation regarding the concept of quality management in tax. Depending on the nature of the comments received in response to the ITC, the AICPA will pursue additional research to determine how and when the SSTSs and/or other guidance may be provided on quality management in tax. At this time, it is not known if or when any changes resulting from the ITC will be implemented.

For additional details and resources, please visit the hub: Proposed Revisions to the AICPA Tax Standards (SSTS).

Request for comments

Respondents are asked to provide comments on the proposed changes and questions listed in the ED and the ITC. Comments are most helpful when they refer to specific questions asked and include the reasons supporting the respondent's view. When a respondent agrees with proposals in the ED or ITC, it will be helpful for the AICPA to be made aware of this view.

Written comments on the ED and ITC will become part of the AICPA public record and will be available on the AICPA's website after Dec. 31, 2022. The AICPA will consider all responses received on or before Dec. 31, 2022.

Please submit comments via our online form. Alternatively, you may email your submission to

Susan C. Allen is a senior manager–Tax Practice & Ethics with the Association of International Certified Professional Accountants, representing AICPA & CIMA. To comment on this article or to suggest an idea for another article, contact Paul Bonner at

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