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Benefits of ERPA

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As Bill Presson explains, recognition as an ERPA can be useful for one who lacks the wider rights of practice that come with the first four categories of practitioners.

31 C.F.R. § 10.3(e)(2):

Practice as an enrolled retirement plan agent is limited to representation with respect to issues involving the following programs: Employee Plans Determination Letter program; Employee Plans Compliance Resolution System; and Employee Plans Master and Prototype and Volume Submitter program. In addition, enrolled retirement plan agents are generally permitted to represent taxpayers with respect to IRS forms under the 5300 and 5500 series which are filed by retirement plans and plan sponsors, but not with respect to actuarial forms or schedules.


Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania



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I found the answer I was looking for.  Apparently absent ERPA you can only represent with respect to examinations of a form you prepared.  Also, signing 5330/945's are two other things I thought of.  Definitely means no VCP's.


Limited representation rights. Unenrolled return preparers may only represent taxpayers before revenue agents, customer service representatives, or similar officers and employees of the Internal Revenue Service (including the Taxpayer Advocate Service) during an examination of the taxable period covered by the tax return they prepared and signed (or prepared if there is no signature space on the form). Unenrolled return preparers cannot represent taxpayers, regardless of the circumstances requiring representation, before appeals officers, revenue officers, attorneys from the Office of Chief Counsel, or similar officers or employees of the Internal Revenue Service or the Department of Treasury. Unenrolled return preparers cannot execute closing agreements, extend the statutory period for tax assessments or collection of tax, execute waivers, execute claims for refund, or sign any document on behalf of a taxpayer.

Austin Powers, CPA, QPA, ERPA

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  • 4 years later...

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