IRS Issues Additions Guidance Related to PTIN Renewal & Suitability Testing

Albeit a little slow, the IRS is finally providing additional information related to the renewal of the PTINs, the requirements for suitability testing and CPE requirements (Notice 2011-80). Here is a rundown:

PTIN Renewal – PTIN renewal will be on a calendar year basis. Thus, the current PTIN registration will expire on December 31, 2011.

  • Renewal Period: Begins on October 15, 2011, and must be completed before January 1, 2012.
  • Renewal User Fee: $64.50
  • Renewal can be completed: Online - Go to and search PTIN, or use form W-12   
  •  Requirements:
    Unlicensed Preparers
    - A preparers other than CPA, EA, or attorney can renew for 2012 without any continuing education requirements or suitability testing. The IRS refers to this as a provisional PTIN.   Additionally, those holding a provisional PTIN may not use the Registered Tax Return Preparer (RTRP) designation. That designation cannot be used until after successfully completing the suitability testing. 
    CPAs, EAs, and Attorneys
    - Renewal is available to those in good standing with their designation.

Provisional PTINS – The IRS will continue to issue provisional PTINs at least through April 18, 2012. Provisional PTINs are PTINs issued to unlicensed tax preparers who have not passed the suitability exam. Once the IRS stops issuing provisional PTINs, tax return preparers who are required to complete the competency test or suitability requirements must complete these requirements successfully prior to obtaining a PTIN.

Continuing Education Requirements – In order for a RTRP or holder of a provisional PTIN to renew their registration for 2013, the individual must have met the IRS requirement for 15 hours of continuing education. Thus, all RTRPs and holders of provisional PTINs must complete 15 hours of IRS-mandated education between January 1, 2012 and December 31, 2012 before they can re-register.

Suitability Testing – Although suitability testing is expected to become available this fall, no specific date is available at this time. It is anticipated that the test will be 2 to 3 hours in duration, include approximately 120 questions, and will be open book, with a copy of Pub 17. Fingerprinting and an FBI background check will be included as part of the process. Testing will be available at 260 Promatic facilities nationwide. User fees for the fingerprinting are estimated to be between $60 and $90 and testing is expected to cost between $100 and $125 (NPRM-REG-116284-11).

  • Lee Reams Sr.

  • Lee T. Reams is the Chief Technical Officer of ClientWhys. He is also an Enrolled Agent having managed a 600-plus client tax practice. Educated as an engineer, with a Bachelor's Degree in Mechanical Engineering, Lee left his engineering career in 1975 to expand his part-time tax practice into a full-time career.

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