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Preparer Electronic Filing Mandate


As of January 1, 2012, any tax return preparer who anticipates preparing and filing 11 or more Forms 1040, 1040A, 1040EZ and 1041 during a calendar year must use IRS e-file (unless the preparer or a particular return is administratively exempt from the e-file requirement or the return is filed by a preparer with an approved hardship waiver). Members of firms must count returns in the aggregate. If the number of applicable income tax returns is 11 or more, then all members of the firm generally must e-file the returns they prepare and file. This is true even if a member expects to prepare and file fewer than 11 returns on an individual basis.Those who are subject to the e-file requirement are referred to as “specified tax return preparers.”

You must be an authorized e-file provider to use IRS e-file. The authorization process generally takes about 45 days.

 Become an Authorized e-file provider

Step 1 – Create an IRS e-services account

 Step 2 – Submit Your Application

Step 3 – Pass a Suitability Check

For step-by-step guidance through the e-file application, download Publication 3112 from IRS.gov.

 Can my Clients Choose Not to File?

Yes.  Even if you are a specified tax return preparer, your clients may independently choose to file on paper.  Preparers should document each client’s choice to file in paper format and keep a signed copy of the statement on file.  Do not send the statement to the IRS or attach it to the client’s tax return.  Instead, attach Form 8948, to your client’s paper return and check box 1.  Include your PTIN on each tax return where requested.  If your clients are filing a joint return, only one spouse’s signature is necessary on the choice statement.

To access Form 8948 in the Keystone Tax Solutions program, from the Main Menu of the Tax Return (Form 1040) select:

  • Miscellaneous Forms
  • Preparer Explanation for Not E-Filing (8948)
Updated on July 13, 2018

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