CGA BC Draws the line at data entry and checking the work

Anything more than data entry and checking that the numbers entered are correct and reconcile to the documentation or to third party information available is considered public practice and CGA's in BC must register and purchase insurance.

But can just the simple act of data entry be cause for concern? Do you have to care about what you enter? Or can you turn a blind eye? See the questions and answers below.

Q#1 If Mary Smith, CGA (a mythical character in earlier posts) calculates the GST/HST return, summarizes the payroll data entry to prepare the PD7A, or prepares a report to calculate the WCB premiums, will she be required to be registered in public practice and purchase insurance by the Code of Ethics for CGA BC?

Answer #1 YES, Mary will be required to register and obtain insurance. Services including summarizing, analysis, advice, counsel or interpretation are considered to be in the practice of public accounting by definition in the CGA BC Code, as is the preparation of tax returns or any other statutory filing.  Payroll, GST/HST and WCB are all statutory filings.

Q: Could Mary get around this by just preparing reports and have the owner sign them?

Answer #2 NO, she can't say she didn't do the work because that would not be telling the truth.

Click here for a link to the CGA BC website for information about public practice registration requirements

Q: For just entering data can CRA invoke 'Civil Penalties'?

Answer #3 YES and this applies to bookkeepers and accountants, and to business owners too! If you haven't ever made time to read why and how this penalty applies, I recommend clicking on this link:

CRA: Third-Party Civil Penalties

See #32 and #33 Clerical or Secretarial Services - these do not include bookkeeping services, such as recording business accounts or transactions and can lead to penalties
See #57 Exemption for Employees - which doesn't include employees of the tax return preparer..
See #72 Disclaimers don't absolve the preparer
See #65/66 Withdrawal where false or suspicious statements
See #67 False statements in prior years must be rectified to extent false statement affects return of current year
See 18 examples of false statements, culpable conduct, tantamount to intentional conduct, indifference and wilful, reckless or wanton disregard of the law