IRS extends acceptance of digital signatures and emailed documents

The Internal Revenue Service is extending until June 30, 2021 the period in which it will accept digitally signed and emailed documents due to the COVID-19 pandemic.

The Internal Revenue Service is extending until June 30, 2021, the period in which it will accept digitally signed and emailed documents due to the COVID-19 pandemic.

In August, the IRS expanded the use of e-signatures as a way to make it easier to file various tax forms and other documents through the end of this year (see story). The IRS also opened a secure messaging service that would allow some documents to be emailed to IRS employees during the pandemic as a way of getting around the millions of pieces of paper mail that accumulated at IRS facilities while they were closed earlier this year. In a memo early this month, Sunita Lough, deputy commissioner of services and enforcement at the IRS, extended the date until the middle of next year.

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Daniel J. McMahon, CPA, is the founder and managing partner of Integrated Growth Advisors (IGA), a value creation and growth advisory firm focused on empowering business leaders to systematically enhance their revenues, profitability, sustainability and value. IGA creates sustainability, transferability and wealth for business owners by addressing common issues relating to growth, control and transition of ownership. IGA has been serving clients throughout the U.S. since 2011.

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Shawn Degnan leads Cross Country Consulting's National Accounting Advisory practice and the Washington, D.C. office, where he is responsible for the overall strategy, client delivery and people, as well as practice and business development. In this role, he guides service delivery for private and public companies, ranging from growth-oriented venture capital and private equity backed businesses to Fortune 500 companies. He brings more than 20 years of experience advising clients on complex technical accounting issues and strategic transactions, including initial public offerings, mergers and acquisitions, carve-outs, and spinoffs. Prior to joining Cross Country, he spent nine years at MorganFranklin Consulting as managing director and commercial market leader guiding all aspects of the firm's commercial practice. He spent the first 12 years of his career with EY in its global capital markets and assurance practices leading delivery of both audit and advisory engagements for large, global SEC registrants and private companies.

Manish Khetan is president of strategic accounts at Xceedance, with 15 years of experience in transforming insurance operations. He leads the North America business and is responsible for business growth and service delivery at Xceedance. He focuses on identifying growth drivers, business planning, capability development, client relations, organizational learning and development, and alternate channels of expansion, including partnerships and acquisitions.

The memorandum extends through June 30, 2021, IRS employees’ ability to accept images of signatures (either scanned or photographed) as well as digital signatures on documents related to the determination or collection of tax liability. The memo also extends until June 30 the date when documents can be sent by email and documents can be transmitted to taxpayers by IRS employees using some secure messaging systems.

“As part of our response to the Coronavirus COVID-19 situation, we are taking steps to protect

employees while still delivering on our mission-critical functions,” Lough wrote. “We are maximizing the ability to execute on critical duties in a remote working environment where employees, taxpayers and their representatives are working from alternate locations.”

The IRS will accept images of signatures in tiff, jpg, jpeg or pdf format, as well as Microsoft Office and Zip compressed files. The IRS will also accept digital signatures that employ encryption techniques such as DocuSign.

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IRS headquarters in Washington, D.C.
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To eliminate mailing documents as much as possible, Lough also recommended IRS employees should use e-fax or secure messaging systems to receive and transmit documents. However, it’s up to the taxpayer’s if they want to transmit documents electronically. If taxpayers aren’t able to e-fax a document or provide it through an established secure messaging service, they can use email with attachments to transmit a document to the IRS if employees take the following steps:

1. Use the IRS’s existing policies for taxpayer contacts to authenticate the identity of the taxpayer or representative by phone to ensure they are authorized to send and receive taxpayer information. In addition, IRS employees need to verbally verify the email address.

2. Advise the taxpayer or representative by phone that communications through unencrypted email via the internet aren’t secure. Employees have to explain that, except for minimal identifying information in the body of the email, such as the name and last four digits of a Taxpayer Identification Number, they should keep sensitive information out of the subject line and body of emails as much as possible, and should use password-protected encrypted attachments via SecureZip or some other encryption method.

3. The taxpayer or representative should include a statement, either in the form of an attached cover letter or within the body of the email, saying, “The attached [name of document] includes [name of taxpayer]’s valid signature and the taxpayer intends to transmit the attached document to the IRS.” If a taxpayer fails to include such a statement, IRS employees will ask for it in a follow-up phone call. Retransmitting attachments isn’t required, however.

4. After IRS employees receive the document via email, they will make a notation in the case files and include the document as well as the email or cover letter in the case file.

5. If a taxpayer transmits a document that requires a manager’s signature at the IRS, such as an executed Form 872, IRS employees will forward the document via encrypted email to their manager for a signature.