PTIN Requirements for Tax Preparers of Exempt Organizations Returns 

    Published December 01, 2011

    Our members have been contacting us regarding whether a preparer tax identification number (PTIN) is required to prepare a Form 990, Return of Organization Exempt from Income Tax, and other returns relating to exempt organizations (e.g., Form 990-EZ, Form 990-T, Form 990-PF, and Form 1023).  There has been some confusion since a tax preparer was generally not required to report his/her PTIN on the 2010 Form 990.  (See 2010 Form 990 Instructions, pages 10-11.)

    According to Notice 2011-6, Implementation of Rules Governing Tax Return Preparers, and information reported on the IRS webpage “Information for Exempt Organizations Tax Preparers,” paid tax preparers are required to have a PTIN to prepare or assist substantially in the preparation of any of the following returns for exempt organizations:

    • Form 1023, Application for Recognition of Exemption under Section 501(c)(3) of the Internal Revenue Code

    • Form 1024, Application for Recognition of Exemption under Section 501(a)

    • Form 1120-POL, U.S. Income Tax Return for Certain Political Organizations

    • Form 4720, Return of Certain Excise Taxes Under Chapters 41 and 42 of the Internal Revenue Code

    • Form 5227, Split Interest Trust Information Return

    • Form 990, Return of Organization Exempt from Income Tax

    • Form 990-EZ, Short Form Return of Organization Exempt from Income Tax

    • Form 990-PF, Return of Private Foundation or Section 4947(a)(1) Nonexempt Charitable Trust Treated as a Private Foundation

    • Form 990-T,  Unrelated Business Income Tax Return

    The AICPA Exempt Organizations Tax Technical Resource Panel wanted to remind preparers that not being required to input one’s PTIN does not mean that you do not need to have a PTIN.  If you have not registered with the IRS under Circular 230’s PTIN requirement, you should not prepare any of the above forms for compensation. 

    At the time of this article, the instructions for the 2011 Form 990 were unavailable.  Please continue to check the AICPA Exempt Organizations Tax page for information on PTIN requirements for 2011 and other information relating to exempt organizations.




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