Principals and Responsible Officials (updated 10/24/2012)
Principals
Generally, the Principal for a business or organization includes the following:
- Sole Proprietorship: The sole proprietor is the Principal for a sole proprietorship.
- Partnership: Each partner who has a 5 percent or more interest in the partnership is a Principal. If no partner has at least a 5 percent or more interest in the partnership, the Principal is an individual authorized to act for the partnership in legal and/or tax matters. At least one such individual must be on the application. See Note below.
- Corporation: The President, Vice-President, Secretary, and Treasurer are each a Principal of the corporation. See Note below.
- Other: The Principal for an entity that is not a sole proprietorship, partnership, or corporation is an individual authorized to act for the entity in legal and/or tax matters. At least one such individual must be on the application.
Note: A large firm with multilayered management, that is not a sole proprietorship, includes only Principals and "Key Persons" who "participate substantially" with control over the firm's electronic filing operations" as Principals on the firm's IRS e-file Application. A large firm usually has subsidiaries or multiple operating divisions/branches. "Key Persons" are individuals other than Principals (as defined above) who participate substantially with control over the large firm's electronic filing operation. "Participate substantially" means participation that is extensive and substantive, and not peripheral, clerical or ministerial.
Responsible Officials
A Responsible Official is an individual with authority over the Provider’s IRS e-file operation at a location, is the first point of contact with the IRS, and has authority to sign revised IRS e-file applications. A Responsible Official ensures the Provider adheres to the provisions of the revenue procedure as well as all publications and notices governing IRS e-file. The Responsible Official may oversee IRS e-file operations at one or more offices, but must be able to fulfill identified responsibilities for each of the offices. If one individual cannot fulfill these responsibilities, add Responsible Officials to the e-file application. To add or change Responsible Officials, a Provider must revise its IRS e-file Application.
Each individual who is a Principal or Responsible Official must:
- Be a United States citizen or an alien lawfully admitted for permanent residence as described in 8 U.S.C. §1101(a)(20) (1994);
- Be 18 years of age as of the date of application; and
- Meet applicable state and local licensing and/or bonding requirements for the preparation and collection of tax returns.
- Each Principal and Responsible Official must answer several personal questions, and sign the Terms of Agreement (TOA) using a PIN, selected during initial registration for e-services. They must declare under penalty of perjury that the personal information is true.
The IRS e-file Application prompts for missing information to ensure that applicants submit only complete applications to the IRS.
Principals and Responsible Officials must submit fingerprint cards or provide evidence of professional status, as described later. The electronic IRS e-file Application prompts with a message to mail fingerprint cards to the IRS with the tracking number provided in the e-Services e-file application when submitting the application. Each Principal and Responsible Official must submit one set of fingerprints
The IRS cannot process applications until it receives all required information and documents. Mail all required documentation to the Internal Revenue Service, Andover Campus, ATTN. EFU Acceptance, Testing Stop 983, at P. O. Box 4099, Woburn, MA 01888-40999, or if by overnight mail to 310 Lowell Street, Andover, MA 05501-0001.
The unique fingerprint cards for IRS e-file are available only from the IRS by calling e-Help, toll-free at (866) 255-0654. A trained specialist must fingerprint the individuals. Most local law enforcement offices and fingerprinting service companies fingerprint individuals for a fee.
In lieu of fingerprints, Principals and Responsible Officials may enter requested information as evidence that they are one of the following:
- Attorney – Must be in good standing of the bar of the highest court in any state, commonwealth, possession, territory, or the District of Columbia. An attorney should not be under suspension or disbarment from practice before the IRS or from the bar of any state, commonwealth, possession, territory, or the District of Columbia.
- Certified Public Accountant – Must have a current license to practice as a Certified Public Accountant in any state, commonwealth, possession, territory, or the District of Columbia. A CPA should not be under suspension or disbarment from practice before the IRS or from practice by a state, commonwealth, possession, territory, or the District of Columbia. Licensed Public Accountants (LPAs) must provide fingerprints.
- Enrolled Agent (pursuant to part 10 of 31 C.F.R. Subtitle A) – Must have a valid Enrolled Agent Number.
- Officer of a publicly held corporation – May be asked to provide information about the exchange where listed and the name under which the stock is traded on corporate letterhead which carries the name of the officer.
- Banking official, bonded and fingerprinted within the last two years – May be asked to provide a copy of the bonding certificate and proof of fingerprinting within the last two years.
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