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.