By now, you’re probably aware of the IRS’s proposed tax preparer registration program. It’s a plan that would require all paid tax return preparers to:

• register with the IRS;
• obtain a “preparer tax identification number,” or PTIN;
• prove their competency by passing an exam (CPAs would be exempt from this requirement); and
• obtain 15 hours of annual CPE (CPAs would be exempt from this requirement).

The plan would also extend the Circular 230 ethics rules to all paid preparers.

The IRS has been moving quickly toward implementing these plans. This summer, the agency rolled out a new online application system for tax preparers, proposed amendments to Circular 230 and announced a $50 fee for tax preparers to obtain a PTIN.

There’s a lot happening on this issue lately — a bit too much, frankly.

We are particularly concerned with a portion of the IRS plan that would require all paid tax return preparers — including non-signing preparers at CPA firms — to obtain a PTIN. It’s not needed, considering that CPAs are already regulated by state boards of accountancy and Circular 230.

The AICPA and the MACPA are urging the IRS to slow down a bit and take a more reasoned, thoughtful approach.

You can help as well.

If you’re a CPA who feels strongly about this issue, please consider sending the following message to the IRS. Your efforts will help ensure that the IRS hears the profession’s message loud and clear.

Simply copy and paste the following message into an e-mail and send it to *public_liaison@irs.gov. (Please note: The asterisk is a required character in the e-mail address.)

Subject line: IRS should slow down implementing tax preparer registration proposal

Body of e-mail:

I urge the IRS to exempt CPA firms from the requirement to register their employees who are non-signing tax return preparers.

I am a CPA and I support the goals to increase compliance and raise the ethical conduct of paid preparers embodied in your proposal to regulate paid income tax preparers. However, the costs and burdens of this proposal go too far, too fast. We need to see a reasoned, rational approach that creates benefits that outweigh the burdens on the CPA preparer community and ultimately the tax-paying public.

CPA firms stand behind the work done by the CPAs and employees of their firms. Requiring PTINs on tax returns should give the IRS enough information to track and weed out incompetent preparers, WITHOUT the need to require PTINs for non-signing preparers who work at CPA firms. CPAs are already regulated by state boards of accountancy and Treasury Department Circular 230, so I believe strongly that the PTIN requirement should not be extended to non-signing preparers at CPA firms.

I request that the IRS exempt CPA firms from the non-signing preparer requirements of the proposed regulations. 

Thank you for your consideration of my thoughts on these important issues.

Thanks in advance for helping us make sure that regulators hear the voice of the profession. We will keep you posted as developments arise.