Although the IRS positions the Annual Filing Season Program (AFSP) as a voluntary program for tax preparers, the IRS implemented limits to representation rights for un-enrolled tax preparers who do not participate in the program.
The stated goal of the AFSP is to recognize the efforts of non-credentialed return preparers who aspire to a higher level of professionalism. To encourage participation, the IRS provides two major benefits to AFSP holders:
- Inclusion in the public directory of tax return preparers
- Limited representation rights
While anyone with a preparer tax identification number (PTIN) can continue to prepare tax returns for compensation, a PTIN-only preparer does not have representation rights after calendar year 2015.
Important deadline for AFSP Record of Completion
The IRS requires CE sponsors to offer the AFTR course in the second half of the year so that tax preparers receive updated training.
As a result, our AFSP Tax Packages are available on our site from June 1st to December 31st.
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All courses must be completed by December 31st
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If you have a PTIN, but not AFSP
Beginning in 2016 only AFSP participants who obtain a Record of Completion have those limited representation rights before the IRS for clients whose returns they prepared and signed.
PTIN holders without an AFSP – Record of Completion or without other professional credentials (CPA, EA and Attorney) will not be able to represent clients before the IRS in any matters and will only be permitted to prepare tax returns.
The new rules limiting representation rights apply to both 1040 and non-1040 preparers.
All preparers need the AFSP Record of Completion for returns completed after December 31, 2015 to engage in limited practice.
If you have a PTIN *AND* AFSP
Tax preparers with a PTIN and AFSP have limited representation rights before limited offices of the IRS with respect to clients whose return they prepared and signed January 1, 2016 or later.
AFSP record of completion participants can represent clients whose returns they prepared and signed, but only before:
- revenue agents,
- customer service representatives,
- the Taxpayer Advocate Service
- and similar IRS employees.
This limited practice right allows a tax preparer to represent a taxpayer in the initial stages of the audit of a return he or she prepared, but the preparer must have a Record of Completion for both the year of the return and the year the IRS initiated the audit.
Unlimited representation rights
Attorneys, CPAs, and Enrolled Agents continue to be the only tax professionals with unlimited representation rights, meaning they can represent their clients on any matters including
- audits,
- payment/collection issues, and
- appeals.
After you receive your Record of Completion
You will be famous
You will be listed on the IRS website in the "Directory of Federal Tax Return Preparers with Credentials and Select Qualifications."
You can look for your listing about the first week in January after completing your AFSP.
You have rights as an AFSP
AFSP participants will have limited representation rights, meaning they can represent clients whose returns they prepared and signed, but only before revenue agents, customer service representatives, and similar IRS employees, including the Taxpayer Advocate Service.
You can add it to your business card
Tax preparers can add the term:
"AFSP - Record of Completion"
to business cards, stationary, email signatures, etc.
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