Note: The following hypothetical questions and answers reflect the opinion of the author and should not be considered authoritative or relied on for license issues or concerns.
The Board of Accountancy for Washington has final authority over all licensee matters and should be referred to for any specific license question. They can be contacted at (360) 753-2586 or via their website at www.cpaboard.wa.gov.
Practice of Public Accounting
Q. I am a licensee and want to use the CPA title. I offer human resource services to the general public. I specialize in locating, interviewing and recommending accounting and financial staff. I do not perform any attest, accounting, or tax work. Is this activity included in “the practice of public accounting?”
A. Yes. In order to use the CPA title when offering those services, you must hold a valid individual CPA license.
Q. I am a licensee and want to use the CPA title. I provide training and seminars to CPAs and CPA firms both directly and through professional associations. I offer training in tax, auditing, accounting and other related fields. I do not perform any attest, accounting, or tax work. Is this activity included in the “practice of public accounting?”
A. Yes. In order to use the CPA title when offering those services, you must hold a valid individual CPA license.
Q. I am a licensee and want to use the CPA title. I provide open-enrollment and in-house seminars and training programs for banks and credit unions. My seminars focus on cash flow and financial statement analysis. I do not perform any attest, accounting, or tax work. Is this activity included in the “practice of public accounting?”
A. Yes. In order to use the CPA title when offering those services, you must hold a valid individual CPA license.
Q. I am a licensee and want to use the CPA title. I provide merger and acquisition consultation to the general public. Is this activity included in the “practice of public accounting?”
A. Yes. In order to use the CPA title when offering those services, you must hold a valid individual CPA license.
Q. I am a licensee and I work in a law firm, not a CPA firm. May I prepare a tax return and sign the return with the CPA title?
A. Yes, provided you hold a valid individual Washington state CPA license to practice public accounting.
Using the Title
Q. Does the Board’s definition of “attest” include compilation services?
A. Yes. Compilation services provided by a CPA are attest services.
Q. My CPA-Inactive certificate (or license) lapsed. Can I put “retired CPA” or
“retired CPA-Inactive” on my resume?
A. No. If you allowed your CPA-inactive certificate or license to lapse, you have no legal usage of the title. You may not put “retired CPA” or “retired CPA-Inactive” on your resume. However, if you submitted appropriate notification to the Board and have retired your CPA license or CPA-Inactive certificate, you may note that as a statement of fact on
Q. I am a CPA-Inactive certificateholder (or licensee). I notified the Board that I am retired. Can I put “retired CPA” on my resume?
A. You may include the words “retired CPA” on your resume provided the information is not provided in a misleading manner. For example, you may not put the words “CPA-Retired” or “Retired-CPA” by your name in the manner of a title. Also, you may not use the words “CPA-Retired” or “Retired-CPA” on your business card. However, you may place the information within the resume as a statement of a fact.
Q. I’m a CPA-Inactive certificateholder who sells insurance. Can I use the “CPA-Inactive” title?
A. Yes, provided you maintain your CPA-Inactive certificate in a status that allows for title use. However, if you provide retirement, estate, and/or financial planning concurrent with the selling of insurance, you need a valid CPA license to use the CPA title.
Q. I passed the CPA exam. Can I call myself a CPA or a CPA-Inactive?
A. No.
Q. I allowed my CPA-Inactive certificate (or license) to lapse. Can I put “Member, Washington Society of CPAs” on my resume?
A. You may put the words “Member, Washington Society of CPAs” on your resume provided the information is factual and is not provided in a misleading manner. For example, you may not put the words “Member, Washington Society of CPAs” by your name in the manner of a title. Also, you may not use the words, “Member, Washington Society of CPAs” on your business card. However, you may place the information within the resume as a statement of fact.
Q. I am a Washington State CPA-Inactive certificateholder. I do not hold a CPA license. May I prepare and/or sign a tax return using the CPA title?
A. No. Only licensed CPAs or CPAs practicing in Washington under a valid grant of practice privileges may use the title CPA when offering to perform, or performing, public accounting services. The practice of public accounting includes: tax, tax consulting, management consulting, accounting, auditing and other attest services. The Board has provided guidance on what other services are included in the practice of public accounting.
Q. I am a Washington State CPA-Inactive certificateholder. I do not hold a CPA license. May I prepare and/or sign a tax return without using the CPA-Inactive title?
A. Yes. CPA-Inactive certificateholders not using the title CPA or CPA-Inactive may perform tax, tax consulting, management consulting, and accounting services; however, they may not use the title CPA or CPA-Inactive in any manner.
Legally Using a CPA Title (A staff interpretation) CPA-Inactive Certificate-holder
A person who holds a valid Washington CPA-inactive certificate (but no license to practice public accounting):
x Must place the word “inactive” immediately following the title “CPA” or “Certified Public Accountant” and in the same font and same size as the title.
x May use the title “CPA-inactive” for occupational purposes (excluding public accounting).
x May use the title “CPA-inactive” on resumes or for memberships.
x May NOT “hold out” to the public for the performance of CPA services.
x Must complete four Continuing Professional Education (CPE) credit hours in professional ethics and regulations applicable to the practice of public accounting in Washington state every three years to maintain an inactive certificate.
CPAs from other states and accounting professionals from other countries
A holder of a license to practice public accounting issued by another jurisdiction may not use the CPA title in Washington state until the individual either submits a complete application for a Washington state license or gains practice privileges.
Individuals holding a license to practice public accounting issued by a foreign jurisdiction may not use the CPA title in Washington state until that individual obtains a Washington state CPA license.
CPAs who are retired from the accounting profession
CPAs who provide confirmation to the Board that they are retired from accounting are exempt from the renewal requirements (CPE and fees); however, retirees may not use the CPA or CPA-Inactive titles.
Expert Witness Services Policy 2002-2
Requirements for Washington State CPA-Inactive Certificateholders
CPA-Inactive certificateholders may use the title CPA-Inactive when performing or offering to perform expert witness services unless the service is related to the following or similar activities, skills, or services:
x Accounting
x Auditing including the issuance of “audit reports,” “review reports,” or “compilation reports” on financial statements,
x Management advisory, x Consulting services, x Preparing of tax returns, or x Furnishing advice on tax matters.
CPA-Inactive certificateholders who testify on another matter (not related to the services, skills, or activities identified above) may use the title “CPA-Inactive” as mandated by RCW 18.04.105 provided they advise the court that they hold a Washington state CPA-inactive certificate and they do not hold a Washington state CPA license to practice public accountancy.
Nothing in this policy is intended to preclude an individual from testifying as a witness to relevant evidence in other than an expert witness capacity.
Compensation
Q. Can I receive stock or other non-cash compensation for services provided to non-attest clients?
A. Yes.
Q. Many firms indemnify clients against the adverse impact of the CPA’s work.
For example, a CPA firm might say that they will complete your tax return for a fee, and if there is a problem with the tax return, they will pay any interest or penalty. Is this a contingent fee?
A. No, because the fee is not dependent upon the finding or result of such service.
Additionally, WAC 4-30-044 states a fee is not regarded as contingent: “if determined based on the results of judicial proceedings or the findings of governmental agencies.”
Q. If a CPA prepares a tax return for a client (the CPA’s work) and will not release the tax return to the client until a past due bill is paid, is this in violation of board rules?
A. No, the tax return is the CPA’s work product and therefore is not a violation of WAC 4-30-051 or RCW 18.04.390. However, upon the client’s request, the CPA must return any client records.
Firm License and Firm Name
Q. I hold a Washington State individual CPA license, and I am planning to establish a CPA firm. I will not use the word “CPA” in my firm title, and I will not offer attest services to the public. Must I apply for a CPA firm license and pay a firm license fee?
A. No. Only those firms that either use CPA in the firm title or offer attest services to the public are required to be licensed by the Board.
Q. I hold a Washington State individual CPA license, and I am planning to establish a CPA firm. I will be offering attest services to the public. I plan to structure the firm as a sole-proprietorship, and I will not have any employees.