"Now, at the 11th hour, just before the registration process is scheduled to begin, some - including the American Institute of CPAs - are demanding that staff members of ‘CPA firms' be exempted from the registration requirements. This flies in the face of why this registration program was set up," Ams said. "The point of the new regulations is to ensure that all tax preparers are accountable for their work in preparing returns, and that should include anyone who paid to prepare all or substantially all of a return, no matter where they may work."

Ams said there shouldn't be a loophole for registration and testing, required of other paid preparers, for CPAs and firm members. He noted since the testing requirements would be faced in over a few years, he saw no reason for a delay.

Another problem, Ams said, is that the definition of CPA firm varies among the states and noted an ongoing discussion among boards of accountancy about the use of fictitious names by businesses owned and operated by CPAs.

Ams' statement continued, "For example, we are aware that an individual who is a CPA owns and operates more than forty H&R Block franchises. Would any or all of these separate offices be considered a ‘CPA firm' for this purpose? Would this be considered one firm?"