After 12/31/15, unenrolled preparers without an AFSP Record of Completion will not have any representation rights.
Effective for tax returns and claims for refunds prepared or signed after December 31, 2015, only unenrolled tax return preparers who have an AFSP Record of Completion for the calendar year of preparation and the calendar year of representation will be permitted to represent taxpayers before the IRS during an examination of a return that they signed or prepared.
Attorneys, CPAs, and enrolled agents will continue to be the only tax professionals with unlimited representation rights, meaning they can represent their clients on any matters including audits, payment/collection issues, and appeals.
Holders of an AFSP Record of Completion will have limited representation rights, meaning they can 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.
PTIN holders without an AFSP Record of Completion or other professional credential will only be permitted to prepare tax returns. They will not be allowed to represent clients before the IRS.
Limitations of unenrolled preparers. Unenrolled return preparers, including PTIN holders of an AFSP Record of Completion, CANNOT perform the following:
Act in a representative capacity before the Appeals and Collection offices (including ACS), and Headquarters officials
Execute closing agreements with respect to a tax liability or specific matter
Extend the statutory period for tax assessments or collection of tax
Execute waivers of restriction on assessment or collection of a deficiency in tax
Execute claims for refund
Receive checks in payment of any refund of IRS taxes, penalties, or interest