By James Hamilton, J.D., LL.M.
The PCAOB has adjusted the implementation schedule of a rule prohibiting audit firms from providing any tax services to persons in a financial oversight role at the company being audited. Rule 3523 applies to all tax services performed during both the audit period and the professional engagement period. The audit period is the period covered by any financial statements being audited, while the professional engagement period begins when the audit firm either signs the engagement letter or begins audit procedures.
The Board has decided to revisit the application of Rule 3523 to tax services provided during the audit period. While revisiting, the Board has adjusted the rule’s implementation schedule as it applies to tax services during the audit period. Specifically, the Board will not apply the rule to tax services provided on or before April 30, 2007 when they are provided during the audit period and completed before the professional engagement period begins.