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No, Corporate Officers or Principals of the firm are not required to complete the registration and application process required for "Large Taxpayers" to participate in IRS e-file. Instead, a "Responsible Official" can be assigned to complete the online registration and application process. The Responsible Official is not required to be a Corporate Officer or a Principal of the firm. The IRS recommends that corporations have two or more Responsible Officials listed on their e-file Application in case the primary Responsible Official is unavailable and the IRS needs to contact them regarding the e-file process of the corporation’s tax return.
Additionally, suitability checks discussed in Publication 3112 are not performed on the Responsible Official, Delegated Official, Corporate Officer, or Principals of entities meeting the definition of a Large Taxpayer since they are required to e-file their return and do not prepare returns for profit. The IRS only performs these suitability checks on applicants that prepare returns for profit.
Sources:
Rev. Proc. 2007-40
Publication 3112 (11/2023)
IRM Part 3. Submission Processing. Chapter 42. Electronic Tax Administration. Section 10. Authorized IRS e-file Providers
IRM Part 3. Submission Processing. Chapter 42. Electronic Tax Administration. Section 4. IRS e-file for Business Tax Returns
Publication 4163 (12/2023)
