New IRS Exam For Tax Preparers Will Not Affect Enrolled Agents

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At present, any person may prepare a federal taxrequirements no later than the initial required renewal
return for any other person for a fee. The IRSdate for tax return preparer registration. Jan. 1, 2011, is
estimates that there are between 900,000 and 1.2the current target date for requiring all paid signing
million paid tax return preparers currently. Attorneyspreparers to be registered and to use a Preparer Tax
and Certified Public Accountants receive a stateIdentification Number (PTIN). The IRS does not plan to
license, while Enrolled Agents receive the privilege toinstitute testing until after registration and mandatory
practice directly from the federal government. OtherPTIN usage is in place.
tax return preparers do not pass any competencyTax Preparer Continuing Professional Education
requirements before they prepare a federal tax return.Tax return preparers who are required to register
This last category of tax return preparer is notmust complete fifteen hours of continuing professional
required to have any minimum education, knowledge,education (CPE) each year, including three hours of
training or skill before they prepare a tax return for afederal tax law updates, two hours of tax preparer
fee. Major changes are on the way.ethics and ten hours of federal tax law topics. Enrolled
Mandatory Tax Preparer RegistrationAgents, Attorneys, and Certified Public Accountants
Certain paid tax return preparers such as attorneys,are not required to complete the new CPE
certified public accountants or enrolled agents arerequirements as they generally must complete
exempt from the new rules. Licensed Publiccontinuing education requirements to retain their
Accountants (LPA) in Delaware, Illinois, Iowa, Kansas,professional credentials.
Michigan, Oregon, and South Carolina do not have theThe Enrolled Agent Advantage
same rights as a Certified Public Accountant and mustUnlike an enrolled agent, this new class of return
also pass the IRS return preparer examination andpreparer may not sign documents for a taxpayer and
satisfy the CPE requirements for tax return preparersmay only represent taxpayers in limited situations
to prepare any federal tax return for compensationbefore revenue agents and customer service
(unless the LPA is an attorney or enrolled agent). Therepresentatives. An un-enrolled
IRS will require all non-exempt individuals who arepreparer’s ability to practice
required to sign a federal tax return as a paid taxbefore the IRS is very limited. Generally, it is limited to
return preparer to register and obtain a preparer taxthe examination function of the Service, and only with
identification number. The IRS will make tax returnrespect to a return he or she prepared. Consequently,
preparer registration effective for three-year periodsan un-enrolled preparer cannot practice before
and require tax return preparers to renew theirappeals officers, revenue officers, and counsel. In
registration and certify continuing education every ataddition, an un-enrolled preparer cannot execute claims
each renewal.for refund, receive refund checks, execute consents
The IRS Examto extend the statutory period for assessment or
The IRS will institute competency testing and willcollection, execute closing agreements, or execute
perform suitability checks on those paid tax returnwaivers of restriction on assessment or collection of a
preparers. Suitability checks often include criminaldeficiency in tax. If you plan to prepare returns, the
background checks and tax compliance checks. A taxenrolled agent designation can open new opportunities
compliance check is a review of thefor your practice and expand your capability to assist
preparer’s personal filing andmore taxpayers. An enrolledagent is the only
payment history. There is noprofessional granted a right to practice directly from
from the testing requirements based on experience.the U.S. government. An enrolled agent may represent
Initially, the IRS will offer two competency examinationsany taxpayer in any state regarding all matters before
for Form 1040 returns. The first examination will coverthe IRS.
wage and nonbusiness income, while anotherWhy Representation Matters
examination will additionally cover small businessWhile more taxpayers are turning to software to help
income (Schedule C). IRS plans call for a third test tothem prepare returns, a program does not exist that
address the competency of the tax return preparercan represent them during an audit. According to
with regard to more complex business tax rules onceenforcement results published by the IRS in 2009,
the initial three-year implementation phase is complete.examinations of individual returns increased over 100%
The IRS is developing transition rules to avoid thesince year 2000. Throughout this period, the number of
interruption of services to taxpayers during the initialexaminations rose every year through 2009.
testing period. The current approach requires paid