AFSP Deadline for Unenrolled Preparers

[taxref]

Technically, the IRS Annual Filing Season Program (AFSP) for unenrolled preparers is a voluntary program.  Indeed, one who does not complete the program is still permitted to prepare tax returns for remuneration.   Unenrolled preparers must be aware, however, that not completing the "voluntary" AFSP can have very negative affects on their practice.

Beginning on 1-1-16, unenrolled preparers who have not competed the AFSP will no longer be allowed even limited representation before the IRS.  Those who complete the program by 12-31-15 will continue to have the same limited representation rights available now.   Needless to say, losing the current limited practice rights could be devastating.

Most of the information put out by the IRS about the AFSP highlights that completion is voluntary, being on its public list of AFSP tax preparers, getting a certificate to display, and being good for marketing.  The losing of limited representation rights is added almost as an afterthought.  I suspect that was done intentionally, in an effort to lay low after the RTRP debacle.  

The AFSP requirements are not onerous at all.  They involve taking 18 hours of specific-course CPE, and passing a 100 question test. 
    

[The Captain]

Oct 10, 2015 8:53:27 GMT -5 taxref said:

Technically, the IRS Annual Filing Season Program (AFSP) for unenrolled preparers is a voluntary program.  Indeed, one who does not complete the program is still permitted to prepare tax returns for remuneration.   Unenrolled preparers must be aware, however, that not completing the "voluntary" AFSP can have very negative affects on their practice.

Beginning on 1-1-16, unenrolled preparers who have not competed the AFSP will no longer be allowed even limited representation before the IRS.  Those who complete the program by 12-31-15 will continue to have the same limited representation rights available now.   Needless to say, losing the current limited practice rights could be devastating.

Most of the information put out by the IRS about the AFSP highlights that completion is voluntary, being on its public list of AFSP tax preparers, getting a certificate to display, and being good for marketing.  The losing of limited representation rights is added almost as an afterthought.  I suspect that was done intentionally, in an effort to lay low after the RTRP debacle.  

The AFSP requirements are not onerous at all.  They involve taking 18 hours of specific-course CPE, and passing a 100 question test. 
    

Tax ref - thanks for posting this.  I've been in big 6 4 or corporate tax my whole career so didn't even know about this.  I always had POA.

How is the AFSP different from an EA?  Do you by any chance know?

I have my MST and as an officer of the corporation don't even need a POA anymore.  I've played around with getting an EA status should I ever go into private practice - but in all honesty don't ever see that happening.

Are you in private practice?  Do you enjoy it - if you don't mind my asking?

[Ombud]

CA & OR preparers are able to complete this thru their mandatory state requirements (10 IRS tax law update hrs, 3 other IRS course hrs, 2 ethics, 5 state law updates in CA for a minimum 20 CPEs due annually by 10/31 or penalty applies)

Needless to say, losing the current limited practice rights could be devastating

for the preparer but not the client.

[taxref]

"How is the AFSP different from an EA? Do you by any chance know?"

The requirements to be an EA are much more stringent than getting the AFSP designation.  Accordingly, EA's can do much more than AFSP's can.  EA's can represent their clients before the IRS, which means the EA can do almost anything a CPA can do in regards to the IRS.  An EA can represent a client in an audit or in collection matters, and more routinely, can have full discussions with the IRS regarding client matters.  

The AFSP designation is for "unenrolled preparers."  An unenrolled preparer is a person who prepares tax returns for remuneration, but is not an attorney, CPA, or EA.  There are no minimum education standards, training, or CPE requirements for unenrolled preparers.   I am an unenrolled preparer, so even though I have a degree in accounting I  have only limited representation powers before the IRS.  I can basically give information to and get information from the IRS regarding my clients, but little else.  I can handle audits for clients, but only regarding returns I have prepared myself.  

Without an AFSP by 12-31-15, I would no longer even be able to perform the tasks mentioned in the last 2 sentences.  I do have occasion to call the IRS several times a year regarding my clients, so that would be a big loss if I couldn't do that.  

I am in private practice, and enjoy it very much.  I get along very well with the boss! :-)  The main drawback is cash flow, which of course is very seasonal.  Although I do accounting all year long for my clients, most of my annual income is concentrated during tax season.