Section 4. Continuing Education

Requirements for Registered Tax Return Preparers

Section 10.6(d)(4) of Circular 230 requires registered tax return preparers to renew their status as a registered tax return preparer as prescribed by the IRS in forms, instructions, or other appropriate guidance. As a condition of renewal, section 10.6(e)(3) of Circular 230 provides that registered tax return preparers must complete a minimum of fifteen hours

required to complete continuing education requirements during 2011.

Individuals who obtain a provisional PTIN in accordance with Notice 2011–6 or this notice are not registered tax return preparers and may not represent that they are registered tax return preparers or have passed the competency examination. Notice 2011–45, 2011–25 I.R.B. 886. Nevertheless, the IRS has decided that these individuals must satisfy the same minimum continuing education requirements that registered tax return preparers are required to complete. Details regarding these requirements are more fully discussed in section 4 of this notice.

Provisional PTIN holders who do not satisfy the minimum continuing education requirements will not be allowed to renew their provisional PTIN. Individuals whose provisional PTINs are not renewed will be required to pass the registered tax return preparer competency examination or otherwise become eligible to obtain a PTIN before preparing all or substantially all of a tax return or claim for refund for compensation.

Section 2: PTIN Renewed Annually on a Calendar Year Basis

Section 1.6109–2(e) provides that the IRS may designate an expiration date for any PTIN or other prescribed identifying number. The regulation further provides that the IRS may prescribe the time and manner for renewing a PTIN or other prescribed identifying number in forms, instructions, or other appropriate guidance.

The IRS has decided that all PTINs (including provisional PTINs) must be renewed on a calendar year basis using the IRS’s online PTIN application available at www.irs.gov or paper application, Form W–12, IRS Paid Preparer Tax Identification Number (PTIN) Application . Individuals who hold valid PTINs must renew their PTIN and pay the required fee (currently $64.25, $50.00 IRS user fee plus $14.25 vendor fee) after October 15th and before January 1st each year. PTINs renewed during this period will be valid from January 1st through December 31st of the following calendar year. PTINs obtained or renewed during a calendar year will expire on December 31st of that year.

Individuals obtaining a new PTIN after October 15th will have the option of receiving a PTIN for the current calendar year or the following calendar year. Individuals who choose to receive a PTIN for the current calendar year will be required to renew their PTIN before January 1st to prepare returns during the following calendar year. Individuals who choose to receive a PTIN for the following calendar year may not prepare tax returns for compensation during the remainder of the current calendar year. Instead, the PTINs issued to these individuals will be valid for the following calendar year.

To assist with the transition to a calendar year renewal period, the IRS has determined that PTINs issued after September 27, 2010 and before October 16, 2011 will expire on December 31, 2011.