Who can participate in the Annual Filing Season Program?

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The Annual Filing Season Program is intended to recognize and encourage the voluntary efforts of non-credentialed tax return preparers to increase their knowledge and improve their filing season competency through continuing education. The program is not directed at or necessary for credentialed preparers such as attorneys, CPAs, enrolled agents, enrolled retirement plan agents or enrolled actuaries. They are already in possession of higher level qualifications.

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 What are the requirements for obtaining an Annual Filing Season Program – Record of Completion?

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In general, to obtain an Annual Filing Season Program – Record of Completion a return preparer must obtain 18 hours of continuing education from an IRS-approved CE Provider. The hours must include a 6 credit hour Annual Federal Tax Refresher course (AFTR) that covers filing season issues and tax law updates. The AFTR course must include a knowledge-based comprehension test administered at the conclusion of the course by the CE Provider. Unenrolled preparers who have passed recognized state or national tests qualify for an exemption from the AFTR course but still must obtain 15 hours of continuing education.

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In addition to completing the appropriate CE courses, the return preparer must also renew his or her preparer tax identification number (PTIN) for the upcoming year and consent to adhere to the obligations in Circular 230, Subpart B and section 10.51.

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Is there a fee to obtain an Annual Filing Season Program – Record of Completion?

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Just as for all CE courses, each IRS-approved CE provider will determine the course participant fee. The IRS Tax Schooling does have a fee to administer the test. However, the IRS does not charge any fee for participating in the program.

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Do I need to notify the IRS once I have completed the Annual Filing Season Program’s Continuing Education requirements?

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No, following the completion of all Continuing Education requirements and renewal of PTIN for the upcoming year, eligible return preparers will receive an email from the IRS. The email will provide instructions for logging into your PTIN account and completing the process. Among the final steps will be a required consent to adhere to specific practice obligations outlined in Subpart B and section 10.51 of Treasury Department Circular No. 230. Following successful completion of these steps, you will be issued an Annual Filing Season Program - Record of Completion.

Please note that it may take up to four weeks following the completion of all requirements for return preparers to receive a Record of Completion and be placed on the Directory of Federal Tax Return Preparers with Credentials and Select Qualifications. Additionally, you will not be issued a Record of Completion until your PTIN is renewed for the upcoming tax year.

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How can I ensure that I receive credit for the continuing education courses that I take?

 

Follow these steps:

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1. Complete your course with us

2. Provide your correct spelling of your name as it appears on your social security card

3. Provide your PTIN by the deadline

4. Double-check that the PTIN you provide matches the PTIN in your welcome letter or online PTIN account

 

You can check your online PTIN account to see a display of the CE courses reported to the IRS for you by providers. 

 

Who is exempt from taking the AFTR course?

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Some unenrolled preparers are exempt from the AFTR course requirement because of their completion of other recognized state or national competency tests. These exempt groups are still required to meet other program requirements, including 15 CE credits (10 Federal Tax Law, 3 Federal Tax Law Updates, and 2 Ethics).

Return preparers who can obtain the AFTR – Record of Completion without taking the AFTR course are:

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• Anyone who passed the Registered Tax Return Preparer test administered by the IRS between November 2011 and January 2013

• Established state-based return preparer program participants currently with testing requirements: Return preparers who are active registrants of the Oregon Board of Tax Practitioners, California Tax Education Council, and/or Maryland State Board of Individual Tax Preparers.

• SEE Part I Test-Passers: Tax practitioners who have passed the Special Enrollment Exam Part I within the past two years

• VITA volunteers: Quality reviewers and instructors 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

How do I obtain an Annual Filing Season Program – Record of Completion if I am exempt from the AFTR course?

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Those who are exempted from the AFTR course must meet the alternative requirements (15 hours of IRS-approved CE, consent to Circular 230 practice requirements, and a valid PTIN for the upcoming filing season) in order to receive an AFSP Record of Completion. Once all requirements are met, the exempted return preparer will be issued a Record of Completion

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A return preparer will not be required to notify the IRS of an exemption. The IRS obtains information about exemptions directly from the testing source

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How and when will I get my Record of Completion?

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Once a return preparer has completed their CE requirements and renewed their PTIN for the upcoming year, they will receive an email from Taxpros@ptin.irs.gov with instructions on how to consent to the Circular 230 practice requirements and receive their certificate in their online secure mailbox.

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Tax return preparers without an online PTIN account will receive a letter with instructions for completing the application process and obtaining their certificates.

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Are credentialed preparers precluded from participating in the AFSP?

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No, as indicated above, this program is not designed, directed or intended for credentialed preparers who already possess a much higher level of qualification. However, if a credentialed preparer seeks to participate in the program, a credentialed preparer would be required to meet the same requirements as those preparers in the exempt category.

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Can an EA take an AFTR course and earn CE credit towards AFSP requirements and/or their EA credentials? 

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No. Due to the high level of knowledge required of Enrolled Agents (EAs), this basic level “refresher” course is not allowed for IRS credit.

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Note: If an EA voluntarily takes an AFTR course (for no IRS credit), it may show in the CE history in their PTIN account, but it will not count towards either AFSP or EA CE requirement calculations.

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What if a preparer has more federal tax update credits than is required for the federal tax law update category in any one calendar year?

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The excess federal tax update credit will count toward their federal tax law requirement for that particular calendar year. The PTIN system will automatically apply the excess credit hours to the federal tax law category, although the excess will still show in the PTIN holder’s Federal Tax Update category in the preparer’s online account.

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Will I still be able to represent clients before the IRS if I don’t participate in the Annual Filing Season Program?

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Yes, as a PTIN holder you will continue to have limited representation rights before limited offices of the IRS with respect to clients whose returns you prepare and sign until December 31, 2015. However, beginning in 2016 only AFSP participants who obtain a Record of Completion will have those limited representation rights before the IRS for clients whose returns they prepared and signed after December 31, 2015. PTIN holders without an AFSP - Record of Completion or without other professional credentials will not be able to represent clients before the IRS in any matters for returns prepared and signed after December 31, 2015.

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Attorneys, CPAs, and enrolled agents will continue to have unlimited representation rights and can represent clients before any office of the IRS.

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I am a non-1040 preparer. Do the limited representation restrictions discussed in the previous FAQ apply to me as well?

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Yes. Both 1040 and non-1040 preparers will need a Record of Completion for returns completed after December 31 to engage in limited practice.

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Are preparers who participate in the Annual Filing Season Program subject to Circular 230 regulations?

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To participate in the AFSP, non-credentialed preparers must agree to adhere to the practice requirements for tax practitioners outlined in Subpart B and section 10.51 of Treasury Department Circular No. 230.

Any return preparer who represents a taxpayer before the IRS is subject to Circular 230.

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Why did the IRS launch this voluntary program? Why not wait to see if Congress passes legislation regarding return preparer oversight?

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The IRS believes in a mandatory competency standard for federal tax return preparers. To this end, legislation continues to be our priority. In the interim, however, this program recognizes the efforts of unenrolled return preparers to improve their professional competency through continuing education. Anyone with a PTIN can prepare a federal tax return, but for those preparers with a PTIN who also work to ready themselves for the filing season through educational efforts, the program affords them a level of differentiation from the rest of the marketplace.

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Do return preparers have to participate in the Annual Filing Season Program?

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No, it is a voluntary program. Anyone with a preparer tax identification number (PTIN) can prepare tax returns for compensation, but continuing education is encouraged for all tax return preparers.

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Will the AFSP – Record of Completion indicate the filing season for which it was issued?

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Yes, each Record of Completion will clearly indicate the filing season for which it is valid (e.g., “Annual Filing Season Program – Record of Completion for Filing Season 2015”

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What term can preparers use on business cards or when advertising their qualifications?

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A preparer may use the term “AFSP – Record of Completion”.

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Is there a limit on the number of years a preparer who passed the RTRP test gets an exemption from the AFTR course and test?

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No. Those who passed the RTRP test will be exempt from the AFTR course as long as the program is in place.

 

How long do states/agencies have to report a preparer’s exemption status?

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Designations must be in place annually by December 31 in order for a preparer to qualify for the AFTR course exemption.  We require all of our students to finish the course by December 18th. 

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Can I take the same program more than once and receive credit?

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As a general rule, preparers should not repeat a program within the same enrollment cycle, if you’re an enrolled agent, or AFSP program year. However, we do understand that a preparer may have a reason to take a program again if they feel they need a refresher on the subject matter.

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Can an identity theft or data security program qualify for continuing education credit?

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Yes, identity theft and data security programs that meet CE program requirements focusing on enhancing tax professional awareness of protecting client data, including review of Publications 4557 and/or 4524 safeguards, can qualify for continuing education credit in the federal tax law category.

 

Are there restrictions on eligibility for the program?

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Yes. Revenue Procedure 2014-42 states that certain people are ineligible to participate in the Annual Filing Season Program, including individuals who are:

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1. Disbarred, suspended or disqualified from practice before the IRS under Circular 230,a.

2. Convicted of a felony involving a financial matter, tax matter, or other violation of the public trust within 5 years preceding the date of application,

3. Enjoined from representing persons before the IRS, preparing tax returns, or engaging in other conduct subject to an injunction under section 7407,

4. Engaged in misconduct that would have violated Circular 230 if the individual were subject to Circular 230, including knowingly providing false or misleading information, or participating in providing false or misleading information, to the IRS, or e. Not in compliance with personal federal tax obligations.

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What happens if I do not agree with an IRS decision that I am ineligible to participate in the Annual Filing Season Program?

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If the IRS believes you are ineligible for the program or proposes to revoke your participation, you will be provided an explanation in writing, along with instructions on how to appeal the decision.