Friday, January 25, 2013


When discussing my proposed industry-administered National Institute of Registered Tax Return Preparers I used RTRP as an example for the designation the organization would provide participating preparers.

But RTRP is not the proper designation.  While the court case shut down the IRS regulation regime – the RTRP testing and CPE requirements - it did not end the need for those who prepare tax returns for compensation to “register” and receive a PTIN.  So, in reality, all individuals with a PTIN are “registered tax return preparers”. 

The obvious choice of designation is “Certified Tax Return Preparer”, as this is a voluntary certification program.  However I expect that the AICPA would be up in arms at the use of the term “certified”. 

“Tax Return Professional” is an option – but this would do a disservice to those preparers who are true tax professionals that choose not to seek the designation.  The new program is, after all, voluntary.  One does not need to have to participate in this program in order to be a “tax professional”.

I would not use “Licensed Tax Preparer”.  As I said in a previous post here, the term license implies government involvement and a legal requirement or distinction.

The designation “Chartered Tax Professional” has been used, but the term “chartered” confuses US tax preparers with European preparers, as the equivalent of a CPA in Europe is a Chartered Accountant.  

There currently are “Accredited Tax Preparer” and “Accredited Tax Advisor” designations.  But I do not think “accredited” is the proper title.  And these titles are already in practice and may be copyrighted by ACAT.

It would seem that “Certified Tax Preparer” would be the best choice.  Do you think the AICPA would protest?  Do we really care if they do?

Whatever title we choose for the designation, if the concept goes beyond the proposal state, I do not want to repeat the error of the “Enrolled Agent” designation – which totally confuses the public.

So what do you think the professional designation for tax return preparers should be?



  1. Robert - I read your posts as often as you post them. I agree with most of what you say. Where I disagree, it's not a total disagreement. This post falls into the latter category.

    I agree with most of what you have put forth here, but I see some issues. The first issue I see is with respect to the use of the word "certified." As you have previously blogged, the EA designation is the highest credential one can obtain in the tax field. EAs cannot use the word 'certified.' I wish that when the choice of changing the designation was put forward a couple of years ago that we could have replaced the EA designation with a title that included the word 'certified." Unfortunately, NAEA could not get a consensus from its membership. So be it. EAs we are.

    Certification implies two things in the mind of the public: one is that some sort of initial and ongoing testing has and is being down to maintain such certification. The other is that the certification is administered by some agency of the government. That is what I believe that the public infers from the word 'certified.'

    The second problem with your proposal that I see is that if EAs have such a hard time educating the public of their qualifications, how can a new designation get any legs? CPAs have done a fabulous job with public awareness. Unfortunately, the perception on the part of most Americans is that CPAs are tax experts by virtue of their designation. I totally agree with you that the letters C P A do not a tax professional make. I see nothing but an uphill battle changing the perception of America. Even if the IRS were to back a designation, I seriously doubt people would wake up. NAEA pours hundreds of thousands of dollars in public outreach and yet I would say 2% of the public could tell us what an EA is. It's a sad state of affairs.

    The best thing for the industry as a whole, should the IRS not prevail, is to back the NSA designations that they have developed through ACAT. Why throw more money at a designation that hardly anyone will understand or recognize?

    I think it's a losing battle. But what to call it? Well, let's look in the dictionary:

    Certified means officially recognize (someone or something) as possessing certain qualifications or meeting certain standards.

    Accredited means officially recognized or authorized.

    They mean the same thing.

    Well, I've had my say. Best to you for a great tax season!

  2. Why bother having a designation at all? Just hang up your certificate saying that you graduated from Such-And-Such Tax School and put it on your business cards and advertising materials, if you're not established enough to rely on your experience to show you know what you're doing, and for some reason have decided not to become an EA.

  3. I spoke to this a bit on Dinesin's blog, but what about something like LTRP? Limited tax return practitioner. It would be a voluntary designation---EA lite. For those whose practice does not require a full EA. It seems that this would eliminate the requirement for well-seasoned preparers, such as yourself, to pass a minimum competency test while at the same time providing serious new preparers with an entry-level credential. If handled well it could eliminate the semantic issue between 'preparation' and 'practice' by spelling out what each level is allowed to do and for whom (e.g. Notice handling, field audits, only returns you have prepared or any return, etc.). Still doesn't deal with the attorney/CPA issue though.