Wednesday, July 2, 2014


The Internal Revenue Service has released Revenue Procedure 2014-42 which formalizes the details of its new Annual Filing Season Program voluntary tax preparer certification program.  

The following is information that I did not report in previous posts on the issue:

·      The annual refresher course comprehension test would be a minimum of 100 questions.  The applicant would have to answer at least 70 percent of the questions correctly to pass.

·      Attorneys, CPAs and EAs who are already covered by Circular 230 requirements would not be required to take the refresher course as a condition of eligibility to apply for a Record of Completion with the IRS. That also applies to individuals who have already passed the RTRP examination, and tax preparers who are licensed or registered by any state, territory or possession of the U.S., including a commonwealth, or the District of Columbia, after passing an examination covering federal tax matters, and tax return preparers who have passed an examination covering federal tax matters administered by an entity recognized by the IRS as an eligible entity.”

There would be no reason for attorneys, CPAs and EAs to apply for Record of Completion – as they will already be included in the public database (for CPAs and attorneys, regardless of any actual tax preparation competence).

Previous IRS releases indicated that “tax return preparers who have passed an examination covering federal tax matters administered by an entity recognized by the IRS as an eligible entity” would include those who have been awarded the Accredited Tax Preparer (ATP) and Accredited Tax Advisor (ATA) designations issued by the Accreditation Council for Accountancy and Taxation (ACAT).

·   Applicants who are exempt from the refresher course will have to successfully complete 15 hours of continuing education from an IRS-approved continuing education provider during the calendar year”, instead of the 18 hours required of all other participants.

·   A tax preparer who receives a Record of Completion under the Annual Filing Season Program, from the IRS may not use the terms ‘certified’, “’enrolled’, or “licensed” to describe this designation or in any way imply an employer/employee relationship with the IRS or make representations that the IRS has endorsed the tax return preparer.

However, tax preparers who receive a Record of Completion for a calendar year may represent that they hold a valid Annual Filing Season Program Record of Completion for that calendar year and have complied with the IRS requirements for receiving the Record of Completion.”

This formalized Revenue Procedure does not address, or change, any of the many objections I, and a lot of others, have to the program.  I still think in its current form it is stupid, and that very few tax preparers will actually "volunteer".


1 comment:

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