New Internal Revenue Service regulations require all paid tax return preparers (including attorneys, CPAs, and enrolled agents) to apply for a Preparer Tax Identification Number (PTIN) — even if the preparer already has one — before preparing any federal tax returns in 2011.  PTIN is required to prepare or submit any return or other form unless it is specifically listed as exempt from the requirement.  Parties needing to register for a PTIN should see here.

IRS officials recently have indicated that the IRS considers all forms filed with the IRS to be a “tax return” for purposes of the PTIN requirement unless specifically exempted by Notice 2011-6.  This construction gives the PTIN requirement sweeping reach.  For instance, TEGE officials recently have confirmed that as Form 1023/1024 is not exempted at this time, the IRS requires that anyone compensated for preparing all or a substantial portion of a 1023 or 1024 (or supervising the preparation of a 1023/1024) to have a PTIN.

IRS Chief  Counsel (Procedure & Administration) has indicated that it is open to receiving comments as to 

IRS Chief  Counsel (Procedure & Administration) has indicated that it is open to receiving comments as to what tax forms should and should not be on the list of exempted forms.  Interested persons may submit their commits to CC:PA:LPD:PR (Notice 2011-6), Room 5203, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044 or electronically to Notice.Comments@irscounsel.treas.gov. Submitted comments should reference “Notice 2011-6” in the subject line of any electronic communications.) 

IRS officials recently have indicated that the IRS considers all forms filed with the IRS to be a “tax return” for purposes of the PTIN requirement unless specifically exempted by Notice 2011-6.  This construction gives the PTIN requirement sweeping reach.  For instance, TEGE officials recently have confirmed that as Form 1023/1024 is not exempted at this time, the IRS requires that anyone compensated for preparing all or a substantial portion of a 1023 or 1024 (or supervising the preparation of a 1023/1024) to have a PTIN. 

IRS Chief  Counsel (Procedure & Administration) has indicated that it is open to receiving comments as to

For Assistance or More Information

If your business needs assistance with non-profit employee benefit, human resources, corporate ethics, and compliance practices, or other related concerns,please contact the author of this  article, attorney Cynthia Marcotte Stamer.

Exempt Organizations Coordinator of the Gulf States Area TEGE Advisory Council, Ms. Stamer is experienced with assisting health care, educational, fraternal benefit societies, trade associations, and others with formation, non-profit and tax-exemption, compensation, benefit and employment matters. Ms. Stamer also speaks and writes extensively on these and other related matters.. For additional information about Ms. Stamer and her experience see CynthiaStamer.com.

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