The IRS hearings on proposals for registering, testing and continuing education for paid tax preparers produce conflicting opinions on who should be required to have a PTIN.
The NSA was represented by John Ams, executive vice president, who testified that all paid tax preparers should be required to have a PTIN. He expanded his comments further, asking the IRS not to exclude those preparers who are subject to state legislation.
In contrast, AICPA vice president Edward Karl suggested the IRS exempt non-signing employees of CPA firms from the requirement to obtain a PTIN. He indicated, “Non-signing employees of CPA firms are indirectly regulated by the states through direct regulation of CPA licenses, as such individuals assume responsibility for the work of their employees. This builds an incentive for managing CPAs to adequately train and supervise staff contributing to the preparation of the return.”
Karl also commented on CPA candidates who are preparing to take the four-part CPA exam. He indicated they should not be required to pay to take the coming paid preparer exam, while at the same time sitting for the CPA exam. He further noted that licensed CPAs are already supervising and training the CPA candidates, as well as taking responsibility for their work product.
Exempting these new CPA candidates from the PTIN requirements would avoid the cost to the firms of taking the qualification exam (cost still to be announced) and the $64.25 PTIN registration fee.
This is just the beginning of the jockeying for an advantage by the various tax preparer interest groups including, individual non-enrolled preparers, national tax firms, Enrolled Agents, CPAs and tax attorneys.