Enrolled Agents and the New IRS Return Preparer Registration Rules

The director of the IRS Office of Professionalwith respect to any entity, transaction, plan or
Responsibility, reserves the enrolled agent designationarrangement.
(EA) for individuals who demonstrate specialCertain tasks do not constitute practice before the IRS
competence in tax matters. The enrolled agents taxand may be performed by anyone, for the moment
proficiency is validated to the IRS by passing a tediousanyway. These tasks include preparation of a tax
three-part examination. Many people incorrectly referreturn, appearing as a witness for a taxpayer before
to EA's as enrolled IRS agents, even though technicallythe IRS, and furnishing information at the request of the
the EA represents the taxpayer and not the IRS. SuchIRS. Tax return preparers, who are not regulated
a thing as an enrolled IRS agent does not exist. Aunder Treasury Circular 230, are known as unenrolled
former IRS employee may apply to become an EAtax return preparers. The term "tax return preparer"
without passing the enrolled exam, provided they havemeans any person who prepares for compensation, or
a minimum of 5 years continuous employment with thewho employs one or more persons to prepare for
Internal Revenue Service during which the applicantcompensation, any return of tax, or any claim for
must have been regularly engaged in applying therefund of tax. A person may be a preparer without
regulations relating to income, estate, gift, employment,regard to professional status, educational qualifications,
or excise taxes.nationality, residence, or business location. It is not
Enrolled agents, Certified Public Accountants, and Taxnecessary to prepare the entire return, a person is a
Attorneys must follow the rules contained Treasuryconsidered a preparer as long as he prepares a
Department Circular 230. This document, available onsubstantial portion of the return.
the IRS website, contains the framework for theSoon the IRS Office of Professional Responsibility will
regulation and registration requirements that theserequire all tax return paid tax return preparers who are
professionals must follow in order to representnot attorneys, certified public accountants or enrolled
taxpayers before the IRS. These Circular 230agents to take a competency test. Currently any
professionals are duty bound to adhere to the strictperson may prepare a federal tax return for any other
rules and regulations that govern their practice. Theseperson for a fee. There are no minimum competency
individuals are considered to "practice before the IRS."standards. The IRS plans to require that paid tax return
Practice before the IRS comprehends all matterspreparers who are not attorneys, certified public
connected with a presentation to the IRS relating to aaccountants, or enrolled agents pass an IRS
taxpayer's rights, privileges, or liabilities under laws orcompetency test. It should be noted that certified public
regulations administered by the IRS. Suchaccountants, attorneys and enrolled agents already
presentations include, but are not limited to preparingtake competency tests. However, in the future the IRS
and filing documents with the IRS for a taxpayer,will study tax return accuracy of attorneys and
corresponding and communicating with the IRS,certified public accountants to ensure that this
representing a taxpayer at conferences, hearings, orexemption to testing requirements is warranted.
meetings with the IRS and rendering written advice