The IRS recently released Notice 2011-6 which provides additional guidance on the preparer tax identification number (PTIN) registration process, including addressing the non-signing preparers of CPA firms, law firms and other professional firms.

In general, Notice 2011-6 does not change the requirement that all individuals who prepare “all or substantially all” of a tax return must register for a PTIN.  Thus, for example, a non-CPA intern who works for a CPA firm and prepares “all or substantially all” of a tax return that his supervising CPA signs will still be required to register for a PTIN. 

Notice 2011-6 does, however, exempt such a non-signing preparer of a CPA firm(and certain other professional firms) from the IRS's examination and continuing education (CE) requirements if:
 
(1) the individual is supervised by a CPA or other Circular 230 practitioner; and

(2) meets certain other requirements as detailed in the notice.

The notice also states that the preparation of certain specified forms does not trigger the requirement to register for a PTIN, such as (among others) Form SS-4, Application for Employer Identification Number; Form W-2; Form 1098 series; and Form 1099 series.  Notice 2011-6 also provides for interim rules involving provisional PTIN holders.