Can an offshore tax preparer prepare US tax returns for my firm?
Sources checked 8 October 2026
Short answer
Yes — with a PTIN, and with the client's consent first. Every person who prepares or assists in preparing a federal return for pay needs a valid PTIN. A foreign preparer without a Social Security number applies with Form 8946. Before your firm shares a client's tax return information with a preparer outside the United States, the client must consent under Treas. Reg. §301.7216-3, using wording set by Rev. Proc. 2013-14.
Every preparer needs a PTIN
The IRS: Anyone who prepares or assists in preparing federal tax returns for compensation must have a valid 2026 PTIN before preparing returns.
That applies to each person individually: every member of an outsourcing team holds their own number.
Form 8946 — and the caution added in 2023
Form 8946 is used by foreign persons without a social security number (SSN) who want to prepare tax returns for compensation.
Since the October 2023 revision, the form also carries a caution: If you're a foreign preparer that resides outside of the U.S. and you obtain a PTIN without a Social Security number, you are not authorized to prepare returns in the U.S. for compensation.
| Revision | Purpose: "…who want to prepare tax returns for compensation" | Caution present |
|---|---|---|
| October 2019 | Yes | No |
| October 2023 | Yes | Yes |
| October 2025 (current) | Yes | Yes |
The purpose line and the caution sit on the same form. Read together, the caution addresses preparing returns in the U.S. on a PTIN issued without an SSN; the form still exists for foreign persons who prepare returns for compensation. If your firm relies on an offshore preparer, ask your own counsel to confirm this reading for your arrangement.
The client's consent comes first
Rev. Proc. 2013-14 restates the rule: where the preparer receiving the information is located outside of the United States, the taxpayer's consent under §301.7216-3 is required prior to any disclosure.
The consent must be signed and dated by the taxpayer, and it must contain this statement:
"This consent to disclose may result in your tax return information being disclosed to a tax return preparer located outside the United States."
If the information includes the client's Social Security number unmasked, a longer statement is required, and the regulation adds limits for Form 1040 series filers. Working with masked SSNs keeps the consent to the short statement.
What stays with your firm
The offshore preparer prepares. Your firm reviews, signs and files under its own EFIN, and collects and keeps the client's consent.
Sources
- IRS — PTIN requirements for tax return preparers (last reviewed 16 Oct 2025)
- Form 8946, Rev. October 2025 (current) — Purpose of Form; caution
- Form 8946, Rev. October 2023 and October 2019 (prior revisions) — 2019: irs.gov/pub/irs-prior/f8946--2019.pdf
- Rev. Proc. 2013-14 — Section 3; consent statements
- 26 CFR 301.7216-3 (eCFR, current)
This page explains published rules. For advice on your firm's own arrangement, ask your counsel.