Does RTRP course qualify for CE for EA's?

[AZ-Tax]

This website says it does:

Do Surgent’s CE courses for RTRPs also qualify for CE for Enrolled Agents?

http://www.rtrpeducation.com/FAQEA.cfm

[Koss]

RTRP and EA

Most RTRP courses also qualify as continuing education for EAs.

There is a very subtle question concerning courses that are designated as RTRP exam preparation courses.

In the previous thread, Piglee wrote:

I am an EA, andI thought that taking the RTRP prep course would be a very good review for all tax laws. I emailed The Tax Book, and they told me that the review class WOULD QUALIFY AS CONTINUNING EDUCATION FOR AN EA. Now you mentioned that it would not.

??????

Here is my response to Piglee, from that thread:

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My comments are based on information on the IRS website.

The IRS FAQ says:

What programs qualify for IRS approval?

1. Is there a minimum length of time that my continuing education program must be to qualify for IRS approved continuing education? (updated 1/3/12)

Yes. Continuing education credit is only given for full contact hours, or multiple thereof. A contact hour is 50 minutes in length, excluding breaks and introductions.

2. May a tax return preparer obtain continuing education credit for completing a Registered Tax Return Preparer competency examination preparation program? (posted 12/6/11)

A tax return preparer can obtain continuing education credit for completing an approved Registered Tax Return Preparer competency examination preparation program until December 31, 2013. A maximum of ten hours will be allowed and it will be qualified as a program under other federal tax law. Enrolled Agents and Enrolled Retirement Plan Agents will not receive continuing education credit for completing any test preparation programs. (Emphasis supplied)

This FAQ can be found at the following link:

http://www.irs.gov/taxpros/article/0,,id=255497,00.html

However...

This is definitely an area of the regulations that is a little ambiguous.

I am the continuing education administrator for two different nonprofit organizations, so this is something that I am intimately familiar with.

I have spoken with the staff of the IRS Return Preparer Office, and they have acknowledged that--

Most professionals would consider the content and subject matter of an RTRP exam prep course to be valid material for a general course in federal tax law. So the same content and subject matter could also be offered as a federal tax course, presumably with the same number of credit hours. And such a course would qualify as valid CE for enrolled agents.

If the staff at the The Tax Book is representing that a particular course is valid CE for enrolled agents, then I think you may reasonably rely on that representation.

From a technical standpoint, I think it comes down to how the course is packaged and registered with the IRS.

Under the new CE provider system, there are actually nine different types of continuing education. When a provider registers a course with the IRS, they have to classify the course according to the target audience and according to the category.

The result is nine different permutations:

(1) RTRP Update
(2) RTRP Federal Tax
(3) RTRP Ethics
(4) RTRP Exam Prep
(5) EA Update
(6) EA Ethics
(7) EA Federal Tax
(8) ERPA Qualified Retirement Plan Matters
(9) ERPA Ethics

The IRS recognizes that many programs will be appropriate for more than one target audience. It is undisputed that most ethics programs are approrpriate for all three types of professionals, and that most update programs are appropriate for EAs and RTRPs.

But according to the IRS guidelines, a provider can't offer an exam prep course to EAs.

A course containing the same content, however, can be registered by the provider as a federal tax course for EAs.
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BMK