Yes, you are subject to the e-file requirement. According to the information provided, if you reasonably expect to prepare and file ten Form 1040 tax returns while working for a firm, and also expect to prepare and file ten Form 1040 tax returns individually as a preparer, you meet the definition of a specified tax return preparer. This is because you expect to file 11 or more returns in total. The definition of a specified tax return preparer, as outlined in the IRS FAQ, includes tax return preparers who, either individually or as part of a firm, expect to file 11 or more returns. Your Preparer Tax Identification Number (PTIN) would be on all of these returns, further indicating your responsibility under the e-file requirement. This requirement is enforced to ensure that tax return preparers who handle a significant volume of tax returns utilize electronic filing, which is more efficient and secure.
Sources:
Publication 3112 (11/2023)
§ 301.6011-7. Specified tax return preparers required to file individual income tax returns using magnetic media.
IRS FAQ
IRS FAQ
IRS FAQ
IRS FAQ
§ 6011. General requirement of return, statement, or list
