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Under existing regulatory authority, the IRS has announced that all paid signing preparers, regardless of credentials or licenses, will be required to register with the IRS after the 2010 filing season. In addition, unenrolled preparers will be required to complete competency testing and mandatory continuing education.
There are still a great many unanswered questions about the new program, including a precise timeline for implementation and the fees that will be charged for registration and renewal, said CCH principal federal tax analyst Mark Luscombe. On the other hand, the IRS has outlined the content for two levels of competency exams.
Once the new regime is in place, all signing preparers will be governed by Circular 230, making them subject to discipline for unethical or unprofessional conduct, although the ability of unenrolled preparers to practice before the IRS will be limited as it is today.
Although the initial IRS program will be aimed at signing preparers and will exempt attorneys, CPAs and enrolled agents from competency testing, the IRS has indicated that it may expand its oversight in the future to include non-signing preparers, testing of professionals and oversight of software if necessary.
