The IRS recently introduced a new program targeting tax preparers who are not Enrolled Agents or CPAs. This program replaces the now defunct RTRP program that covered the same group of tax preparers. This new designation is titled IRS Annual Filing Season Program. Upon completion of the filing program requirements, tax preparers are granted a record of completion certificate for public display and are labeled with this level of competency and professional suitability on the IRS’ website. Another great benefit to tax preparers who complete the program is the ability to contact the IRS to discuss returns they prepared. Preparers who do not complete the AFSP loose this privilege and cannot communicate with the IRS regarding their clients.
Tax Preparers wishing to obtain and be able to advertise this level of mastery must complete the following requirements annually prior to December 31st.:
• 18 hours of IRS Continuing Education in the following areas:
◦ 6-hour Annual Filing Season Refresher Course & Exam
◦ 10 hours of General Tax Topics*
◦ 2 hours of Ethics
• Maintain/Renew your PTIN (preparers tax identification number)
One common point of confusion in the tax preparer community is “Do I have to meet all of these requirements to become an AFSP preparer, or is there an easier way?” The answer depends on how you can answer the following question… Are you an “Exempt Preparer” if so, there are significantly easier annual requirements that pertain to you. Exempt preparers are anyone who fits into one of the following 5 categories:
• Anyone who passed the Registered Return Preparer Test (RTRP) between November 2011 and January 2013.
• Preparers who are both actively and currently registered with any state-based program that has testing and/or CE requirements: Oregon, California, and Maryland.
• SEE Part 1 test-passers (the “individual” portion of the test for becoming an Enrolled Agent). Test must have been passed within the last two (2) year.
• VITA/TCE volunteers: Quality reviewers, instructors, and return prepares with active PTINs
• Other accredited tax-focused credential-holders: The accreditation Council for Accountancy and Taxation’s Accredited Business Accountant /Advisor (ABA), and Accredited Tax Preparer (ATP) programs.
Both exempt preparers and non-exempt prepares must maintain their PTINs annually and also consent to Circular 230 requirements just the same, but Exempt Preparers need only to complete 15 credit hours of IRS sanctioned continuing education, comprised of:
• Ten (10) hours of other Federal Tax Law topics
• Two (2) hours of Ethics
• Three (3) hours of Federal Tax Law Updates
The Exam consists of 100 multiple choices questions. The exam is delivered online through our website and must be completed within a 3 hour time allotment. The exam is open book and will cover the material presented in all 3 chapters of the AFSP Course materials. Successful passing of the exam requires at least a 70% score, and multiple attempts are acceptable until the 70% passing grade is achieved. The Exam, as well as all other requirements must be successfully completed prior to December 31st to qualify for the AFSP course record of completion from the IRS.
The Record of Completion will be delivered through the IRS’ PTIN website. Once a qualifying tax preparer renews their PTIN for the coming tax season they will receive a secure email from the IRS indicating that their document is available through the IRS PTIN account secure mailbox. There are no additional fees required for obtaining the record of completion, simple renewal of your PTIN (preparer’s tax identification number) is sufficient. The certificate covers practice for the entire year and expires December 31st of the calendar year.
Consent to Circular 230 restrictions A requirement for receiving your record of completion will be consenting to the duties and restrictions relating to practice before the IRS in subpart B and section 10.51 of Treasury Department Circular No. 230.
Modification to limited practice permissions Only tax return preparers who have a record of completion under the Annual Filing Season Program for the calendar year of preparation and the calendar year of representation will be permitted to represent taxpayers before the IRS during an examination of a return that they signed or prepared. Enrolled Agents, Attorneys, and CPAs continue to have unlimited representation rights and can represent clients before any office of the IRS and do not have to complete the Annual Filing Season Program to do so.