By Jennifer L. Cryder, CPA, PICPA CEO
The pandemic has disrupted every aspect of our personal and professional lives. Perhaps nothing more significant has changed in our professional lives than remote work. Unlike some, the CPA profession was better prepared to face these unforeseen challenges because of statutorily granted practice mobility. With remote work becoming the norm, CPAs should know the nuances of working remotely and the importance of their designated principal place of business.
The Pennsylvania CPA Law defines principal place of business as “The location of the principal office where a certified public accountant practices public accounting.” This definition virtually mirrors the definition in the Uniform Accountancy Act (UAA), the AICPA and National Association of State Board of Accountancy’s model licensing law. The UAA stipulates that if a CPA has 150 credit hours of education with an accounting concentration, at least one year of acceptable experience, and the successful completion of the Uniform CPA Examination, licensed CPAs could more readily practice across state lines.
It may not, however, be that simple. CPAs must use their best judgement to make the principal place of business determination, as Stephanie Saunders, chair of NASBA’s Uniform Accountancy Act Committee, explained at the 2022 NASBA Eastern Regional Meeting. For instance, a CPA who is living in New Jersey and working from home and is hired by a Virginia accounting firm whose clients are in Virginia, should be licensed in Virginia. While this CPA lives in New Jersey and never physically works in Virginia, the principal place of business in this case is Virginia since that is the location of the firm and clients.
In some cases, the principal place of business may not be enough to prevent the need for a second license. If a CPA establishes residency in Colorado, for example, and provides a few professional services to an employer or client in the state, that person must have an active CPA license in Colorado, even if their principal place of business continues to be in another state like Pennsylvania.
The bottom line: Be sure you read the statutes of the states in which you conduct business, and consider consulting with legal counsel to ensure you are licensed in the right jurisdiction. For more information on this issue, I encourage you to visit www.nasba.org/licensure/substantialequivalency.
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