As we emphasized during last year’s ClientWhys fall seminars, 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, including California Registered Tax Preparers (CRTPs), will only be accorded to those preparers participating in the IRS Annual Filing Season Program and who obtained their annual Record of Completion. CRTPs, by virtue of their CTEC registration, are exempt from the IRS program education and testing requirements, but they are still required to affirmatively agree to abide by Sub Part B of Circular 230 in their IRS PTIN account to obtain their record of completion for 2016.
Having a record of completion enables CRTPs to retain representation rights for returns they prepared and signed, but only before revenue agents, customer service representatives and similar IRS employees, including the Taxpayer Advocate Service. A CRTP must have a record of completion for both the year of return preparation and the year of representation to represent his client.
A CRTP must only go to his IRS PTIN account and check the box that he agrees to in order to abide by Circular 230 Sub-Part B. Sub-Part B is the same rules of practice that EAs, CPAs and attorneys must abide by. The IRS has created a A CRTP must only go to his IRS PTIN account and check the box that he agrees to in order to abide by Circular 230 Sub-Part B. Sub-Part B is the same rules of practice that EAs, CPAs and attorneys must abide by. The IRS has created a how-to video (and blog article) to demonstrate how to sign the Circular 230 consent and print the Record of Completion.
The deadline for signing the Circular 230 consent and printing the Record of Completion is April 18, 2016. In a conference call with the IRS, we learned that a significant number of CRTPs have not taken the time to obtain their 2016 Record of Completion. THIS IS EXTREMELY IMPORTANT FOR EVERY CRTP. DO IT TODAY.
To begin, visit www.IRS.gov/ptin and click “Renew or Sign up now”.