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IRS Reminds Tax Return Preparers of Limited Practice Changes and Announces Lower PTIN Fee

posted Nov 4, 2015, 9:43 PM by Zaher Fallahi

The Internal Revenue Service (“IRS”) reminded non-credentialed tax return preparers of major upcoming changes regarding which tax return preparers can represent clients in matters before the IRS beginning in 2016, and take action by Dec. 31, 2015, to avoid being affected.  Enrolled agents, certified public accountants and attorneys are categorized as credentialed tax preparers.


Effective for tax returns and claims for refunds prepared and signed after Dec. 31, 2015, the limited right to represent clients before the IRS held by non-credentialed preparers will be accorded to only those preparers who participate in the IRS Annual Filing Season Program, a voluntary continuing education (CE) program. The changes in the limited representation rules have no impact on tax returns prepared and signed by non-credentialed preparers before January 1, 2016. 


Non-credentialed tax return preparers who participate in the Annual Filing Season Program will continue to have limited rights to represent clients before the IRS. This enables them to represent taxpayers whose returns they prepared and signed, but only before revenue agents, customer service representatives and similar IRS employees, including the Taxpayer Advocate Service (TAS). The tax return preparers must participate in the Annual Filing Season Program for both the year of return preparation and the year of representation to their represent of their client.


There are no changes to representation rules for enrolled agents (EAs), certified public accountants (CPAs) and lawyers. These professionals will have unlimited practice rights and can represent any taxpayer before any IRS office, including collection and appeals, regardless of whether they prepared the tax return in issue.   


To participate in the Annual Filing Season Program, non-credentialed tax return preparers must complete either 15 or 18 hours of continuing education (CE) from IRS-approved CE providers. The CE must be completed by Dec. 31, 2015, in order to receive a 2016 Annual Filing Season Program Record of Completion.


Effective Nov. 1, 2015, the annual fee for 2016 preparer Tax Identification Number (PTIN)s will be $50 for both new applications and renewals. The IRS will collect $33 as a user fee to support program costs and a third-party vendor will receive $17 to operate the online system and provide customer support. The current PTIN fee is $64.25 for a new registration and $63 for renewal.


Zaher Fallahi, Esq., CPA, is a Tax Relief Lawyer, practices as Los Angeles Tax Defense Attorney and Orange County Tax Defense Attorney, and assists clients in solving their IRS problems with respect to OVDP, FBAR, FATCA and tax audit.  Zaher Fallahi has been rated 10 out of 10 by Avvo . About 1.8% of the US lawyers are also CPAs, and Zaher Fallahi is one of them. Zaher Fallahi was named a top tax attorney in September 2015  Telephones: (310) 719-1040 (Los Angeles), (714) 546-4272 (Orange County), e-mail