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Update on New IRS Voluntary Program for Unenrolled Tax Return Preparers

July 23, 2014


On June 27, 2014 we provided information on the IRS’s announcement regarding the new voluntary program for unenrolled tax return preparers. The announcement explained that preparers can obtain a record of completion from the IRS that attests to the fact that they have completed continuing education, renewed their PTIN, and consented to adhere to practice obligations in Circular 230, Section 10.51. Since the initial announcement, the IRS has provided more detail on the program.

The requirements are different for tax return preparers who are considered exempt and those who are not exempt.

A preparer is considered exempt if they have done one of the following:

  • Passed the Registered Tax Return Preparer (RTRP) test that was administered by the IRS between November 2011 and January 2013
  • Met the testing and continuing education requirements in a state based return preparer program such as those that California, Oregon, and Maryland have in place
  • Passed the Special Enrollment Exam Part I within the past two years as of the beginning of the 2015 filing season
  • Are a quality reviewer or instructor under the VITA program and have an active PTIN
  • Have obtained an accredited tax-focused credential such as those from the Accreditation Council for Accountancy and Taxation’s Accredited Business Accountant Advisor and Accredited Tax Preparer programs.

Exempt Preparers
If an unenrolled preparer meets one of the above requirements and they wish to participate in this program, they must meet the following requirements:

For 2015:

  • Eight (8) hours of continuing education consisting of:
    • Three (3) hours of federal tax law updates
    • Three (3) hours of other federal tax law topics
    • Two (2) hours of ethics
  • Renew (or obtain) a PTIN
  • Consent to adhere to specific practice obligations outlined in Circular 230, Section 10.51

For 2016 and beyond:
The continuing education requirement will be 15 hours with an additional seven (7) hours of other federal tax law topics. All other requirements remain the same.

For more information see Reduced Requirements for Exempt Individuals on the IRS website.

Non-Exempt Preparers
Unenrolled tax return preparers who are non-exempt and wish to participate in this program must meet the following requirements:

For 2015:

  • Eleven (11) hours of continuing education consisting of:
    • Complete a six (6) hour Annual Federal Tax Refresher course that covers filing season issues and tax law updates as well as a knowledge-based comprehension test administered at the end of the course by the CE provider.
    • Three (3) hours of other federal tax law topics
    • Two (2) hours of ethics
  • Renew (or obtain) a PTIN
  • Consent to adhere to specific practice obligations outlined in Circular 230, Section 10.51

For 2016 and beyond:
The continuing education requirement will be 18 hours with an additional seven (7) hours of other federal tax law topics. All other requirements remain the same.

For more information see General Requirements of the IRS Annual Filing Season Program on the IRS website.

It is important to remember that the continuing education requirements must be met each year for enrolled preparers who choose to participate in the program.

Once the requirements are met the preparer will receive a Record of Completion from the IRS.

For general information on the new IRS program and Circular 230 see the following:

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2018 Changes to Form 8867 (Preparer Due Diligence Checklist)
November 9, 2018

2018 Depreciation Changes
October 18, 2018

2018 Tax Law Changes that are Directly Reported on Form 1040
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IRS Tax Transcripts Changes
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Revised 2018 Schedule A due to Tax Cuts and Jobs Act Changes to Itemized Deductions
August 29, 2018

Additional Updates
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