All posts by Jane Supnet

Electronic Return Originators(ERO) Due Diligence requirements.

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Welcome to Tax Courses Online Newsletter. We strive to keep you current on information relevant to Tax Preparers.

Electronic Return Originators(ERO) Due Diligence requirements.

Having been an ERO since 1994, it’s been a while since I have looked at Publication 1345 Handbook for Authorized IRS e-file Providers of Individual Income Tax Returns Publication 1345. IRS updated the publication in 2022, so it was worth a look.

Some of the important issues are outlined below.

1. Please check the accuracy of your current information in your e-services account. We are required to update our account information within 30 days if there is a change of address, telephone number, email address, change of business structure, or a responsible individual.

IRS also requires Website addresses if any information is being collected from taxpayers for federal income tax returns on that website.

2. EROs are required to be diligent to prevent fraud in the IRS’s E-file system. If the ERO is also the preparer of a return, extra due diligence is required for returns involving Earned Income Tax Credit (EITC), a popular area of abuse.

3. As an ERO, we are required to:
Confirm the identity of all parties listed on the tax return.
Inspect a valid government-issued ID for all new taxpayers to the firm.

Examples of valid IDs are:
Government-issued driver’s license or ID Card
Government employer, school, state, military, national ID Card
Voter ID or visa or passport.

Verify a taxpayer’s Social Security card or ITIN letter for accuracy
Verify the W-2 matches the identification number provided
Verify and input the address on a W2 record that differs from the filing address on the tax return

4.. Other requirements for ERO’s
File returns within 3 days of obtaining signatures
Do not charge a separate fee for direct deposit
Do not have any of the taxpayer’s refund directly deposited into the ERO or preparers account
Do not file any return before receiving the Form W2, W2G, or Form 1099R. If any of these forms cannot be obtained Form 4852 Substitute for Form must be used.
Any changes to the tax return after the taxpayer has signed the electronic transmission form (Form 8879 or Form 8453) if the amount of change to AGI is more than $50 or the change to tax is more than $14 requires the taxpayer to sign a new form.

5. The following signature methods are acceptable:
Handwritten signature on an electronic signature pad
Handwritten signature on a display screen using a stylus
a digitized image of a handwritten signature that is attached to an electronic record
the typed name typed into the signature block on a website form

Additional requirements if the signature is obtained remotely:
Capture the digital image on the signed form
Capture the date, time, and IP address
The electronic signature process must be able to generate evidence that the person is the person the electronic signature belongs to and that the identified person is actually associated with the electronic record.

6. Create a written Information Security Plan for your Tax & Accounting Practice using publication 5708 as a guideline.

7. Add multi-factor authentication to the basic security steps

My final advice is when in doubt, get more information and document, document, document.

Thank You,
The Tax Courses Online team

Continuing Education Requirements for Enrolled Agents

Continuing Education Requirements for Enrolled Agents
Enrolled agents must complete 72 hours of continuing education (CE) every three years. This includes a minimum of 16 hours annually, with at least 2 hours on ethics. All CE courses must be offered by IRS-approved providers.
The last digit of your Social Security number determines the enrollment cycle.

For newly enrolled agents, CE hours required in the year of initial registration are prorated at 2 hours per month, starting from the registration month through December. For instance, if you register in August, you will need a total of 10 hours, including 2 hours dedicated to ethics.


Renewal Application Periods for Enrolled Agents
1. Social Security Numbers Ending in 0, 1, 2, or 3
o Renewal Period: November 1, 2024, through January 31, 2025
For example: If you enroll in May 2024, your enrollment cycle ends in December 2024. You will need to complete 16 hours of CE, including 2 hours of Ethics.
2. Social Security Numbers Ending in 4, 5, or 6
o Renewal Period: November 1, 2025, through January 31, 2026
For example: If you enroll in May 2024, your enrollment cycle ends in December 2025. You will need a total of 40 hours of CE: 16 hours for 2024 and 24 hours for 2025, including 4 hours of Ethics.
3. Social Security Numbers Ending in 7, 8, or 9
o Renewal Period: November 1, 2026, through January 31, 2027
For example: If you enroll in May 2024, your enrollment cycle ends in December 2026. You will need a total of 64 hours of CE: 16 hours for 2024, 24 hours for 2025, and 24 hours for 2026, including 6 hours of Ethics.

CTEC RENEWAL NOW OPEN

2024/2025 Registration for Renewal of CTEC Licensed Tax Preparers opened August 1st.

IMPORTANT DATES:
Aug 1st through Oct 31st registration fee $33.00 plus $2 processing fee

Nov 1st through Jan 15th registration fee $33.00 plus late fee $55.00 ($88.00) plus $2 processing fee

Dec 31st  CRTPs who plan to participate in the IRS voluntary Annual Filing Season Program (AFSP) must have their CTEC renewal registration completed no later than December 31, 2024, which is required by the IRS.

Jan 16th and later registration must include a new 60 hour qualifying education course and you must register as a new preparer.

Tax preparers who do not complete their registration by Oct 31st will have expired licenses until they renew and are not allowed to prepare tax returns.

Education providers have 10 days after you complete your courses to submit them to CTEC. Students who wait too long to complete their education risk the possibility of not having it submitted in time to renew. They would then have to retake the 60 hour qualifying education course to obtain a license for the 2020/2021 year.

Continuing Education requirements:
20 hours total
• 10 hours Federal Tax Law
• 3 hours Ethics
• 2 hours tax law updates
• 5 hours California State tax law

CTEC Continuing Education requirements for 2024

10 CPE Federal Tax Law, 3 CPE Update, 2 CPE Ethics, 5 CPE California Tax Law (20 total CPE)

Tax Courses Online Course Breakdown

Federal Tax Law

Total available 13 CE

Pick any of the above courses to get to 10 CPE

Both of these are required courses

California Law

Total Available  5 CPE

All California Courses are required

You must take all required courses to satisfy the CTEC continuing education requirements before you can renew your license

1095-A and (PTC) Premium Tax Credit

Tips for preparing returns with Form 1095-A and PTC

If a taxpayer brings in Form 1095-A and there is no Advance Premium Tax Credit then we need to look up the SLCSP (Second Lowest Cost Silver Plan) premium to see if they qualify. When a taxpayer pays full price for their insurance the Form 1095-A comes with 0.00 in column B. That is not correct. This number (SLCSP) needs to be looked up and entered into the software for column B in order to properly calculate the Premium Tax Credit.
The Marketplace only puts numbers in Column B when there is Advance PTC it will be up to us to look up SLCSP for all others.

Healthcare.gov

“If you paid full price and want to see if you qualify for a premium tax credit based on your final 2015 income
Use the Health Coverage Tax Tool to find the premium for the second lowest cost Silver plan (SLCSP) that applied to you for 2015. (If you paid full price, this information will be missing from your 1095-A.)
Use this figure to fill out Form 8962, Premium Tax Credit (PDF). When you’re done, you’ll find out if you qualify for a premium tax credit based on your final 2015 income.
If you qualify for a premium tax credit, you must complete Form 8962 and attach it to your federal income tax return.”

If a taxpayer brings in Form 1095-A and they have utilized the Advance Premium Tax Credit all we have to do is input that information into our software and our software should calculate correctly.

Identity theft: 7 Steps to protect Client Data

 

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Identity theft is an increasing problem for tax preparers.  Tax preparation offices are great places to hack. Here are some best practices  we need to do to protect us and our clients. 

1. Create logins and passwords to your system that are hard to hack.

  • Use the maximum characters allowed.
  • If you want to use for example:
    • “I was born in Houston Texas in  January 5,1992” You could use iwbihtj592 and then add symbols and numbers to complete the maximum characters allowed.
    • “My mother’s maiden name is smith and she married John Doe in Los Angeles ” could translate to mmmnisasmjdila.
    • Song lyrics work to. ” Rudolf the red nose reindeer had a very shiny nose and if you ever saw him” could translate to rtrnrhavsnaiyesh

These are things that make no sense to someone else but are easy for you to remember.

Using a password generator will do this for you and you only have to remember one PW

2. Change passwords on a regular basis. If you haven’t done so recently take the time to revamp your passwords. Passwords should be changed at a minimum of once per year. Every 90 days is even better. Chances are we are not going to change our passwords every 90 days. So, make your passwords strong as possible

3. Always encrypt and password protect any data sent to clients. Emails are easy to hack using encryption will help safeguard the data. If your software offers a secure file exchange portal be sure and check it out. Those portals are designed to exchange information more securely.

4. Always Encrypt any hard drives that contain client data. Encrypting the hard drives adds another level of security.

5. Update your firewall,anti-spyware and anti-virus software. Regularly check for the latest update and security patches for your software.

6. If you are also and ERO, you should regularly check your e- services account on a regular basis. IRS updates our e-services accounts on a regular basis. We should be checking our account to look for abnormal activity. If it appears that your EFIN may have been compromised notify the IRS immediately.

  1. Never click on links in emails. Always go directly to the website.

Tax preparers  are subject to the Gramm-Leach Bliley Act and the FTC Financial Privacy and Safeguards rules. We are required to monitor, evaluate and adjust our security practices to protect client data. Penalties may apply for failure to do so. IRC imposes criminal and monetary penalties for knowingly or recklessly making unauthorized disclosures.

7 things Unenrolled Return Preparers should know.

 

1. Beginning January 1, 2016,  new rules  will limit unenrolled return preparers  representing clients before the IRS to only those preparers who have  an Annual Filing Season Program (AFSP)  record of completion from the IRS.

2. If you are a tax  preparer, with an active PTIN, but no professional credentials and you do not participate in the AFSP, you are authorized to prepare tax returns but not represent clients .

3. Returns prepared and signed after December 31, 2015, you will not be allowed to represent clients before the IRS (even if you are the preparer of a return).

4. Limited representation rights  will allow  unenrolled return preparers with AFSP record of completion to represent clients whose returns they  actually prepared before the IRS.

5. They cannot represent clients whose returns they did not prepare and they cannot represent clients regarding appeals or collection issues even if they did prepare the return in question.

6. IRS defines an unrolled return preparer  is an individual other than an attorney, CPA, enrolled agent, enrolled retirement plan agent, or enrolled actuary who prepares and signs a taxpayer’s return as the paid preparer, or who prepares a return but is not required  to sign the return.

7. To participate in the Annual Filing Season Program a tax preparer needs to take 18 hours of continuing education from an IRS approved CE provider by December 31st each year.

This includes:

  • A six hour Annual Federal Refresher course (AFTR course)
  • 10 hours of Federal Tax Law and
  • Two hours of ethics.

Certain tax preparers are exempt from the AFTR course:

  • Anyone who passed the Registered Tax Return Preparer test between November 2011 and January 2013.
  • Return preparers who are active registrants of:
    • Oregon Board of Tax Practitioners.
    • California Tax Education Council (CTEC).
    • Maryland State Board of Individual Tax Preparers.
    • Tax preparers who passed the Special Enrollment Exam part 1 within the past two years.
    • VITA/TCE volunteers
    • Other accredited tax focused credential-holders
      • Accreditation Council for Accountancy
      • Taxation’s Accredited Business Accountant/Advisor (ABA)
      • Accredited Tax Preparer Programs

PTIN holders who meet one of these exemptions will need to complete annually:

  • 3 hours of federal tax law updates
  • 10 hours of  federal tax law
  • 2 hours Ethics

 

Annual Filing Season Program Requirements

To participate in the Annual Filing Season Program a tax preparer needs to take 18 hours of continuing education from an IRS approved CE provider by December 31st each year.

This includes:

  • A six hour Annual Federal Refresher course (AFTR course)
  • 10 hours of Federal Tax Law and
  • Two hours of ethics.

Certain tax preparers are exempt from the AFTR course:

  • Anyone who passed the Registered Tax Return Preparer test between November 2011 and January 2013.
  • Return preparers who are active registrants of:
    • Oregon Board of Tax Practitioners.
    • California Tax Education Council (CTEC).
    • Maryland State Board of Individual Tax Preparers.
    • Tax preparers who passed the Special Enrollment Exam part 1 within the past two years.
    • VITA/TCE volunteers
    • Other accredited tax focused credential-holders
      • Accreditation Council for Accountancy
      • Taxation’s Accredited Business Accountant/Advisor (ABA)
      • Accredited Tax Preparer Programs

PTIN holders who meet one of these exemptions will need to complete annually:

  • 3 hours of federal tax law updates
  • 10 hours of  federal tax law
  • 2 hours Ethics

Only Unenrolled Return Preparers who complete these requirements annually will allowed the limited representation rights before the Internal Revenue Service

The limited rights for unenrolled return preparers with AFSP certificate allow them to only 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. They cannot represent clients whose returns they did not prepare and they cannot represent clients regarding appeals or collection issues even if they did prepare the return in question.

After PTIN renewal season begins in October, a Record of Completion will be generated to you once all requirements have been met, including renewal of your PTIN for 2016 and consent to the Circular 230 obligations

 

CTEC Renewal and Continuing Education Requirements

Things CTEC registered preparers should know about their registration.

CTEC made a policy change starting January 15,2013 preparers who do not renew their registration by January 15th of each year will have to retake the 60 hour qualifying education course. This new policy shortens the grace period for late renewals from 12 months to 10 weeks.

Preparers should know that their registration expires on October 31st of each year until renewed.  A preparer whose registration is expired is not permitted to prepare Tax Returns until their renewal application is processed by CTEC.

The following is a list of CTEC renewal requirements and important dates.

Renewal Requirements:

  • Renew by October 31st pay $33.00 renewal fee.
  • Renew after October 31st and pay and additional $55.00 late fee.
  • Renew after January 15th retake 60 hour qualifying education course.
  • Have a current $5000.00 tax preparer bond

Continuing Education requirements:
20 hours total

  • 10 hours Federal Tax Law
  • 3 hours Ethics
  • 2 hours tax law updates
  • 5 hours California State tax law

CTEC Continuing Education Requirements

CTEC Continuing Education  requirements for 2016

10 CPE Federal Tax Law, 3 CPE Update, 2 CPE Ethics, 5 CPE California Tax Law (20 total CPE)

Tax Courses Online Course Breakdown

Federal Tax Law

Total available 12 CPE

Pick any of the above courses to get to 10 CPE

Both of these are required courses

California Law

Total Available  5 CPE

All California Courses are required

You must take all required courses to satisfy the CTEC continuing education requirements before you can renew your license