WISP - EFIN, PTIN and ERO

Pub 1345 p 23

What are the EFIN, PTIN and ERO Duties After Submitting the Return to the IRS

Below is a breakdown of these responsibilities:

1. Record Keeping and Documentation Requirements

• Duty: EROs must retain copies of the taxpayer’s e-filed return, including the IRS e-file Signature Authorization (Form 8879 or Form 8453), and all associated documentation for a minimum of three years.
• Purpose: Maintaining these records allows the IRS to audit or review the e-filed returns as necessary, ensuring traceability and compliance with IRS regulations.
• Data Security: Records should be stored securely, following IRS data protection standards, to prevent unauthorized access.

2. Providing Information to the Taxpayer

• Duty: EROs are responsible for informing the taxpayer about the status of their return after it has been transmitted to the IRS. This includes confirming whether the IRS has accepted or rejected the return.
• Purpose: Clear communication helps manage taxpayer expectations and allows them to take action if the return is rejected.
• Compliance: Properly document all communications with the taxpayer regarding the return’s status.

3. Acknowledgments of Transmitted Return Data

• Duty: EROs must monitor the IRS acknowledgment system to confirm if the transmitted return was accepted or rejected.
• Purpose: Timely verification helps address any issues promptly and ensures that the return is filed correctly.
• Next Steps: If the return is accepted, the ERO can complete the submission process; if rejected, the ERO must take corrective actions.

4. Resubmission of Rejected Tax Returns

• Duty: If the IRS rejects the tax return, the ERO is responsible for informing the taxpayer, resolving the issue, making necessary corrections, and resubmitting the return.
• Purpose: Ensures that the taxpayer’s filing is processed in a timely manner, helping them avoid late penalties.
• Compliance: Accurately document the error, corrective steps taken, and final resubmission to keep a record of compliance.

5. Advising Taxpayers about Refund Inquiries

• Duty: The ERO should advise taxpayers on how to track their refund status using IRS tools, such as the "Where's My Refund?" online portal.
• Purpose: EROs assist taxpayers in understanding the process and timeline for receiving refunds.
• Compliance: EROs should avoid providing specific refund dates, as delays can occur, but they can provide general guidance on accessing official IRS resources.

6. Refund Delays

• Duty: EROs must inform taxpayers that refunds may be delayed for various reasons, such as processing times, errors in filing, or IRS verification needs.
• Purpose: Helps manage taxpayer expectations and reduce concerns over delayed refunds.
• Compliance: If the IRS notifies the ERO of any specific delay reason (such as identity verification), the ERO should inform the taxpayer as appropriate.

7. Refund Offsets

• Duty: EROs must inform taxpayers that refunds can be reduced or offset if they have certain debts, such as overdue federal or state taxes, student loans, or child support.
• Purpose: Providing this information helps taxpayers understand potential reductions in their refund amount.
• Compliance: Document any advice given to taxpayers regarding refund offsets for record-keeping purposes.

8. Disposal of Taxpayer Information

• Duty: EROs must securely dispose of any unnecessary taxpayer data once it is no longer needed, following IRS guidelines for data destruction.
• Purpose: Secure disposal of taxpayer information protects against data breaches and aligns with IRS and FTC requirements for data security.
• Compliance: Proper documentation of data disposal methods and dates is recommended for regulatory compliance.

Summary of ERO, EFIN, and PTIN Holder Duties After Submitting Returns

• EFIN Holders: Maintain secure data handling, documentation, and compliance standards, including IRS record-keeping and data security requirements.
• PTIN Holders: Ensure confidentiality of taxpayer data, accurate documentation of any taxpayer interactions, and secure handling of sensitive information.
• EROs: Manage the entire post-filing process, from record retention and taxpayer communication to error resolution, refund guidance, and secure data disposal.

By fulfilling these duties, EFIN and PTIN holders, along with EROs, uphold the integrity of the IRS e-filing system, ensure regulatory compliance, and protect taxpayer information.

Here’s a template to capture the key duties of an EFIN and PTIN holder serving as an ERO after submitting a tax return to the IRS. This template allows for tracking compliance, identification of responsible parties, and record-keeping dates:

ERO Duties After Submitting the Return to the IRS	Yes	No	N/A	Firm	Data Security Coordinator	Date
1. Record Keeping and Documentation Requirements
2. Providing Information to the Taxpayer
3. Acknowledgments of Transmitted Return Data
4. Resubmission of Rejected Tax Returns
5. Advising Taxpayers about Refund Inquiries
6. Refund Delays
7. Refund Offsets
8. Disposal of Taxpayer Information
IRS Mandated Standards - will you	Yes	No	N/A	Firm	Data Security Coordinator	Date
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.

How to Use This Template:

• Yes/No/N/A: Indicate whether each duty has been completed (Yes), not completed (No), or is not applicable (N/A).
• Firm: Enter the name of the firm responsible for each action.
• Data Security Coordinator: Enter the name or title of the person overseeing data security for the specified duty.
• Date: Record the date each duty was completed or reviewed.

This structured template helps ensure all critical ERO responsibilities are fulfilled post-submission, from record-keeping to taxpayer support, refund status, and secure data disposal.