Authorized IRS e-file provider question ...

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Q. (con't.)

Who is authorized to complete the e-Service registration (i.e. CPA/certified CPA, attorney, Chief Financial Officer) and authorized to submit IRS e-filings and other e-services functions (IRS TIN Matching) for our company? Define all "tax professionals." Do we need to also complete a PTIN application? Can a CPA apply for an PTIN?

 

A.

Regarding your first question about who is authorized to complete e-Services registration with the IRS: this document from the IRS says you must register if you are “doing business as an individual representing yourself or your corporation.” (https://www.irs.gov/pub/irs-utl/eservices_registration_process_-_09hf-3.pdf)

If you are going to file for or use e-Services, you must have a PTIN.

However, this more general document (https://www.irs.gov/pub/irs-utl/e-services_for_circular_230_participants_and_tax_professionals.pdf) says:

“Who can use e-services?
Available to all: e-file application; PTIN; e-services registration
Available to payers: TIN matching
Available to those who e-file five or more accepted returns in a year or Circular 230 participants: disclosure authorization; transcript delivery system; electronic account resolution”

Here’s how the IRS characterizes tax preparers: “Any tax professional with an IRS Preparer Tax Identification Number (PTIN) is authorized to prepare federal tax returns. However, tax professionals have differing levels of skills, education and expertise.” See https://www.irs.gov/tax-professionals/understanding-tax-return-preparer-credentials-and-qualifications.

This article goes on the say that IRS-licensed agents, CPAs and attorneys have “unlimited representation rights” with the IRS; return preparers who don’t fall into these categories, and PTIN holders without professional credentials have limited representation rights—meaning they are allowed only a limited degree of client representation in matters of audits, appeals and so on.

To your next question, let me refer you to this page on the IRS site, which was just updated: https://www.irs.gov/tax-professionals/ptin-requirements-for-tax-return-preparers.

The IRS says, “Anyone who prepares or assists in preparing federal tax returns for compensation must have a valid 2017 PTIN before preparing returns. All enrolled agents must also have a valid PTIN.” By this standard, yes, if you or someone on your team is preparing or helping prepare tax returns, they should have a valid 2017 PTIN. That would include a CPA, but anyone can obtain one.

On this basis, I believe any designated representative from your organization can register for e-Services, but everybody that has access to e-Services or is involved with tax matters should have a PTIN.

The IRS e-help Desk number is 866-255-0654 if you need more specific information, but these links do a pretty good job of walking you through the process.

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