Under Rule 3523, "Tax Services for Persons in Financial Reporting Oversight Roles
," independence is impaired if, during the period of the audit and professional engagement, an accounting firm or any affiliate of the firm, provides tax services to a person in a financial reporting oversight role
(FROR) or to his or her spouse or dependents.
In an early alert to members, CPCAF director Lillian Ceynowa wrote that "some center members believed that the performance of tax services for the audit client's individuals in a financial reporting oversight role
would not result in a threat to the auditor's independence." Moreover, Ceynowa said, "tax services to individuals in a financial reporting oversight role
have been a mainstay of the tax practices of a majority of the center's members without creating independence problems for many years."
The PCAOB also adopted an amendment to Rule 3523, Tax Services for Persons in Financial Reporting Oversight Roles
, to remove verbiage that stipulated that firms providing tax services during the portion of the audit before the professional engagement period are not independent of the audit client.
* Services to (1) certain corporate managers who serve in financial reporting oversight roles
or (2) their immediate family members.
* Provide tax services to certain members of management (and immediate family members) who serve in financial reporting oversight roles
at an audit client.