SECTION 2. BACKGROUND — Internal Revenue Bulletin 2010-48

On September 30, 2010, the Treasury Department and the IRS published final regulations in the Federal Register, T.D. 9501, 2010–46 I.R.B. 651 [75 FR 60309], requiring paid tax return preparers who prepare all or substantially all of a tax return or claim for refund to register with the IRS to obtain PTINs. The IRS also announced that the online PTIN application system and paper application, Form W-12, IRS Paid Preparer Tax Identification Num- ber (PTIN) Application, are available for tax return preparers to apply for a PTIN.

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 recognizes, however, that some tax return preparers required to obtain a PTIN may not have a social security number. In particular, a foreign person (who, for example, may prepare returns for United States taxpayers

2010–48 I.R.B. 781 November 29, 2010

tious religious objection will be considered to have complied with the requirement to obtain a PTIN set forth in the final regulations under section 1.6109–2 if they complete the online application or submit a completed paper Form W-12 by the later of (1) January 31, 2011, or (2) 10 days after the first day on which they prepare all or substantially all of a U.S. tax return for compensation, and they submit a completed PTIN supplemental application, Form 8945 or Form 8946, including any required additional documentation, within 60 days after the completion of the online application or submission of the paper Form W-12. The applicable PTIN user fee must be submitted with the online application or paper Form W-12. Tax return preparers who are foreign persons or U.S. citizens without a social security number due to conscientious religious objection who have not obtained a PTIN but are considered to be in compliance with section 6109 under this revenue procedure may prepare and sign U.S. tax returns and claims for refund as a paid tax return preparer without furnishing a PTIN or other identifying number for returns prepared on or before October 31, 2011.