Yesterday the IRS issued an announcement (IR 2015-123) that may be misleading to California tax preparers registered with CTEC.

Posted by Lee Reams Sr. on

The IRS’s voluntary education program for unenrolled return preparers and others, the Annual Filing Season Program (AFSP), includes the provision that unenrolled return preparers will no longer have limited representation rights if they do not have a “record of completion” for the year for which the return was prepared and for the year of the representation, effective for tax returns signed after December 31, 2015. 

For unenrolled return preparers, except CTEC registered preparers (CRTPs), this requires a preparer to complete 12 hours of CE credits and take and pass the 6-hour Annual Federal Tax Refresher (AFTR) from an approved IRS education provider.  

However, CTEC registered preparers are EXEMPT from taking the 6-hour AFTR course and need only complete the normal CTEC education requirements, which are 3 hours of federal update, 2 hours of ethics, 10 hours of federal tax subjects and 5 hours of California tax subjects.

Some CE providers are taking advantage of CRTPs with solicitations that misleadingly imply that all unenrolled return preparers must complete the 6-hour Annual Refresher Course. Although the 6 hours will count toward federal CE hours if you take the course, the course is not required for CRTPs to obtain the “Record of Completion” that is needed to continue to have limited representation rights.

If you are a CRTP, to obtain your Record of Completion each year, you must:

  • Complete your required CTEC education requirements.
  • Complete your annual registration with CTEC.
  • Renew your PTIN with the IRS.
  • When the IRS notifies you by e-mail, go to your PTIN account and sign an agreement to abide by the provisions of Circular 230, Subpart B (the same provisions that apply to enrolled preparers). 

The IRS will then issue you a “Record of Completion” and add you to the IRS database as having a record of completion for the year. 

If you have any questions about your CTEC education requirements, feel free to reach out to us at 1-800-442-2477 x1 or visit our website at