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The Revised Definition of Public Practice FAQ 

A new public practice registration category, “Limited Registration – Other,” became effective July 1, 2010. 

The following information explains some of the services offered to the public that qualify for this type of registration.

 


Defining Public Practice 

Where can I locate the definition of what is considered providing public practice services? 

The CGA-BC Code of Ethical Principles and Code of Conduct (the Code) defines what the practice of public accounting means. This Code is found on the CGA-BC website in the “Ethics and Standards” section of the members’ area. This definition was revised September 24, 2011.


How does the Code define the practice of public accounting? 

The Code states:

“The practice of public accounting means:

(a)   Providing or offering to provide one or more of the following services to the public:

  • an assurance engagement;
  • a specified auditing procedures engagement;
  • a compilation engagement;
  • an accounting service insofar as it involves summarization, analysis, advice, counsel or interpretation but excluding an accounting service which is incidental to the provider’s primary occupation which is not public accounting;
  • forensic accounting, financial investigation or financial litigation support services;
  • advice, counsel or interpretation with respect to taxation matters; and
  • the preparation of a tax return or other statutory filing.

(b)  A member who is "employed" in the practice of public accounting is not considered to be "engaged" in the practice of public accounting. This exemption does not apply to employees of firms that are owned, operated or controlled by a non‐arms length person or persons, and that are not CGA, CA or CMA firms registered with, and regulated by, their respective associations.


What are the public practice registration categories and what types of services does each category permit? 

  1. Full Registration
    Choose one of two types of full registrations:

    • Full Public Practice Registration – Assurance
      Registrant may provide all types of financial statement engagements, including audits and review engagements.  In addition, both corporate and personal tax services may be provided.
       
    • Full Public Practice Registration – Compilation and Tax
      Registrant may only provide compilation financial statement engagements. In addition, both corporate and personal tax services may be provided.
     
  2. Limited Registration – T1
    Registrant may only provide T1 preparation services.
     
  3. Limited Registration – Other
    Registrant may provide statutory filing services (with the exception of personal and corporate tax returns), forensic accounting, financial investigation, financial litigation support or any other accounting service insofar as it involves summarization, analysis, advice, counsel or interpretation.


What is meant by “preparation of statutory filings?” 

Any filings that companies must make as required by law are considered statutory filings.  They commonly include, but are not limited to, GST/PST, payroll withholdings, WorkSafeBC reports, T4s and T5s.  The preparation of these filings includes the calculation of the data reported on the filings form as well as the completion of the form itself.

If I register in the “Limited Registration – Other” category, can I file T1s and T2s? 

The preparation and filing of personal and corporate tax returns (T1s and T2s) is not permitted by members registered on a “Limited Registration – Other” basis.  Members preparing and filing personal tax returns (T1s) require a “Limited Registration – T1” registration.  Members preparing and filing corporate tax returns (T2s) require a full registration. 

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FAQs by Members 

As a CGA who is self-employed, what services may I provide to the public that do not require registration in public practice?  

Without registering in public practice, a member may provide the following services to the public:

  • data-entry to trial balance,
  • bank reconciliations,
  • accounts receivable reconciliation and ageing,
  • accounts payable reconciliation and ageing,
  • inventory reconciliation, and
  • payroll calculations with no filings.

As a CGA who is self-employed, what services may I provide to the public when registered in public practice on a “Limited Registration – Other” basis? 

By registering in public practice on a “Limited Registration – Other” basis, a member may provide the following services to the public:

  • data-entry to trial balance,
  • bank reconciliations,
  • accounts receivable reconciliation and ageing,
  • accounts payable reconciliation and ageing,
  • inventory reconciliation,
  • payroll calculations and all payroll forms, including payroll remittances, T4s, T4 summaries and Record of Employment forms,
  • WorkSafeBC Employer Payroll and Contract Labour Report preparation,
  • GST/PST remittances,
  • T5s,
  • Not-For-Profit information returns, and
  • all other statutory filings with the exception of T1s, T2s and T3010s (Registered Charity Information return).

I provide data-entry services to my clients and am not registered in public practice. Is it acceptable to provide financial statements to these clients? 

No, you cannot provide financial statements to your clients if not registered in public practice. This applies to software program generated statements as well as those prepared manually. Clients may erroneously associate the provider of the financial statements as the party who has the capability to prepare them. This association must be reserved for the client’s public practitioner.

Although many software programs have the capability to arrange the trial balance into a financial statement format, members solely providing services not requiring registration in public practice are not permitted to provide financial statements to their clients. Limit yourself to providing your clients with a trial balance.


I provide data-entry services to my clients and am registered in public practice on a “Limited Registration – Other” basis. Is it acceptable to provide financial statements to these clients? 

No, you cannot provide financial statements to your clients if your registration in public practice is solely on a “Limited Registration – Other” basis. This applies to software program generated statements as well as those prepared manually. Clients may erroneously associate the provider of the financial statements as the party who has the capability to prepare them. This association must be reserved for the client’s public practitioner who is registered in public practice on a “full” basis.

Many software programs have the capability to arrange the trial balance into a financial statement format but members registered on a “Limited Registration – Other” basis are not permitted to provide financial statements to their clients. Limit yourself to providing your clients with a trial balance.

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 Registration Information 

Where do I find “Limited Registration – Other” registration requirement information? 

Public practice registration information is located in the public practice section of the CGA-BC website. 

How do I register for the “Limited Registration – Other” category? 

Obtain your copy of the “Limited Registration – Other” registration form in the public practice section of the CGA-BC website. 

Who do I contact if I have further questions about the “Limited Registration – Other” registration? 

For registration processing information, contact: 

[sdomeikiene#cga-bc,org]Sandra Domeikiene
Public Practice Administrator - Registrations
(604) 637-6803 or toll free 1 (800) 565-1211 extension 803

For information about registration requirements, contact: 

[kfiorini#cga-bc,org]Karen Fiorini, CGA
Manager, Quality Assurance
(604) 730-6231 or toll free 1 (800) 565-1211 extension 231

or

[bilk#cga-bc,org]Brigitte Ilk, CGA
Manager, Public Practice Research & Development
(604) 629-8363 or toll free 1 (800) 565-1211 extension 363

 

When does the requirement for CGAs to register for the “Limited Registration – Other” category become effective? 

Registration for this new category was mandatory as of July 1, 2010.backtotop 

 

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