Damn, is it possible I will need to be fingerprinted again? The IRS is planning to roll out a fingerprinting process, which will likely impact the non-CPA staff of CPA firms who are considered non-signing preparers and are required to obtain a preparer tax identification number in order to prepare tax returns. So there is a possibility of me needing to get fingerprinted again, since the Service prefers an all or non approach.
I have had to be fingerprinted in Chicago, because I was a partner in a retail operation and they required all owners be fingerprinted. When I was working with financial advisors I needed to be fingerprinted three times. Once for the initial registering with a Broker Dealer, a second time when they accidentally terminated my paperwork and a third time when they switched Broker Dealers.
Notice 2011-6 exempts non-signers of CPA firms from the continuing education and testing requirements of the registration program but did indicate that the IRS would require non-signers to undergo tax compliance and suitability checks, once they become available. The IRS has now indicated that fingerprinting, a one-time practice, is considered part of its suitability check process. The formal procedures, timing and costs for fingerprinting have not yet been announced by the IRS. I am sure my employees cannot wait.