The Internal Revenue Service released information Tuesday on the procedures that foreigners and U.S. citizens without a Social Security number because of religious objections can use to register as tax preparers.

Revenue Procedure 2010-41 describes the procedures that foreign persons and U.S. citizens without a Social Security number due to conscientious religious objection must follow to obtain a Preparer Tax Identification Number, and provides temporary relief during the 2011 filing season for these individuals who experience a delay in obtaining their PTINs.

The IRS opened its online PTIN application system last month and made available its paper application, Form W-12 to allow tax return preparers to apply for a PTIN. All tax preparers will be required to have a PTIN for next tax season.

"There are a number of transition issues we are also working through as we implement the return preparer initiative," said IRS Commissioner Doug Shulman during a keynote speech Tuesday at the AICPA's Fall Tax Meeting. "One of the first out of the gate was foreign PTINs for those paid return preparers outside of the United States who lack a Social Security number, but prepare U.S. tax returns for their clients. We recognized the hurdles they faced, and in response, are providing them with some needed flexibility."


Both the online system and the Form W-12 generally require an individual to submit a valid Social Security number to obtain a PTIN. The IRS said it recognizes, however, that some tax preparers may not have a Social Security number. “In particular, a foreign person (who, for example, may prepare returns for United States taxpayers living in a foreign country) may not have a Social Security number and may not be eligible to obtain one,” said the revenue procedure. “Similarly, a U.S. citizen may not have a Social Security number due to a conscientious religious objection to applying for and receiving a Social Security number.”
Some churches object to Social Security numbers, claiming they violate the Biblical admonitions against idolatry and slavery.

The IRS provided a two-part process for getting a PTIN if the tax preparer lacks a Social Security number. It first involves completing either the online PTIN application or a paper Form W-12.  Second, a foreign person must provide a completed Form 8946, “PTIN Supplemental Application for Foreign Persons Without a Social Security Number,” which is a paper form. A U.S. citizen without a Social Security number due to conscientious religious objections must provide a completed Form 8945, “PTIN Supplemental Application for U.S. Citizens Without a Social Security Number Due To Conscientious Religious Objection,” which is a paper form.

Additional documentation must also be submitted with the Forms 8945 and 8946, as required by the instructions accompanying the forms. Forms W-12, 8945 and 8946 and the accompanying instructions are available on IRS.gov.

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