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August 2011

PTIN FINGERPRINTING OF NON-SIGNING PREPARERS

Currently IRS plans to initiate a fingerprinting process as a part of its background and suitability checks under the PTIN program.  As presently planned, this program would impact the non-CPA staff of CPA firms who are considered non-signing preparers and are required to obtain a preparer tax identification number (PTIN). 

Notice 2011-6 exempts these non-signers from the continuing education and testing aspects of the registration program but does not exempt them from the background and suitability checks under the Treasury Regulations. The IRS has now indicated that fingerprinting, a one-time practice, is considered part of its suitability check process.

The formal procedures, timing and costs for fingerprinting have not yet been announced. The TSCPA Federal Tax Policy Committee plans to comment on this issue in an effort to exempt non-CPA staff from this fingerprinting as we did successfully with the respect to the testing requirements.  

http://www.irs.gov/taxpros/article/0,,id=238830,00.html

                                                                                                                                                                                     


FTP COMMITTEE RESPONDS TO IRS ON EX PARTE COMMUNICATIONS AND CONTINUING EDUCATION PROVIDER PROCESS

The Federal Tax Policy Committee issued comments letters this week to the IRS on two recent notices, Notice 2011-61, regarding IRS’s continuing education provider standards and process for registered tax return preparers, and Notice 2011-62, proposed revenue procedures that update existing rules on permissible communications between the Office of Appeals and other parts of the agency.

Comments on Notice 2011-61

http://www.tscpa.org/Content/Files/pdf/Resource%20Center/Tax%20Issues%20Community/Letters/2011/tscpaLTRirs201161cpe.pdf

Comments on Notice 2011-62

http://tscpa.org/Content/Files/pdf/Resource%20Center/Tax%20Issues%20Community/Letters/2011/tscpaLTRirsNotice1162ExParteComm.pdf