Form 8821, Tax Information Authorization: Letting Someone See Your IRS File

Sometimes you do not need someone to fight the IRS for you. You just need someone to look. Your bookkeeper needs to see what the IRS has posted. Your adult child is helping you sort out an old balance. A preparer needs your wage and income records to finish a return. For that, the IRS has Form 8821, Tax Information Authorization.

The current form is Form 8821 (Rev. January 2021). Its instructions are dated September 2021. Both are on IRS.gov.

What Form 8821 does

According to its instructions, Form 8821 authorizes any individual, corporation, firm, organization or partnership you designate to inspect and/or receive your confidential information, verbally or in writing, for the type of tax and the years or periods you list. It is a consent to disclosure under IRC 6103(c), which permits the IRS to disclose return information to persons you designate.

Notice who can be a designee: any individual or organization. Unlike Form 2848, the person does not have to be an attorney, CPA or enrolled agent. That is what makes Form 8821 useful for family members, bookkeepers and businesses.

What Form 8821 does not do

The instructions are direct. Form 8821 does not authorize your designee to speak on your behalf, to execute a request to allow disclosure to another third party, to advocate your position regarding federal tax laws, to execute waivers, consents or closing agreements, or to represent you in any other manner before the IRS. The designee may not substitute another party as your designee.

Two more limits worth knowing:

• A designee is never allowed to endorse or negotiate your refund check or receive your refund by direct deposit.
• If you want someone to represent you, you need Form 2848 instead. The comparison is in Form 2848 vs. Form 8821.

Line by line

Line 1, taxpayer information. Your name, taxpayer identification number and street address. The instructions note that the address on Form 8821 will not change your address with the IRS; use Form 8822 or 8822-B for that. If a joint return is involved, the designee is authorized only for you. Your spouse or former spouse must submit a separate Form 8821.

Line 2, designee. The designee's full name, address and CAF number. If the designee already has a CAF number from a prior Form 8821 or Form 2848, use it. If not, enter "NONE" and the IRS will issue one directly to the designee. If you name more than two designees, check the box and attach a list. If you want the designee to receive copies of notices and communications the IRS sends you, check the box under the name. You may not designate more than two designees to receive copies of notices for the same matter. See the CAF number explained.

Line 3, tax information. This is the heart of the form. Enter the type of tax, the tax form number, the years or periods, and the specific matter. For example, "Income, 1040" for "2024." You can write a range such as "2021 thru 2024." Do not write "All years," "All periods" or "All taxes." The instructions say any authorization with a general reference will be returned.

You may list the current year, prior years, and future years, but the IRS will not record on the CAF system future years that exceed 3 years from December 31 of the year the IRS receives the form.

Column (d) lets you limit what the designee can see, for example lien information or a balance due amount. Enter "not applicable" if you are not limiting it.

The Intermediate Service Provider box. Also on line 3. If you do not check it, your designee cannot use a privately owned Intermediate Service Provider to retrieve your information indirectly. The designee can still get it directly from the IRS through its e-Services Transcript Delivery System.

Line 4, specific use not recorded on the CAF. Check this only for a one-time or specific purpose the IRS does not record centrally, such as disclosure to a lender or an educational institution, background check disclosures, or requests involving certain forms the instructions list. If you check it, the designee should mail or fax the form to the IRS office handling the matter. A specific-use authorization does not revoke prior authorizations.

Line 5, retention or revocation of prior authorizations. If line 4 is not checked, the IRS will automatically revoke all prior tax information authorizations on file unless you instruct otherwise. To keep a prior one, check the line 5 box and attach a copy of the one you want to keep. This catches people all the time. Filing a new 8821 for your new bookkeeper can silently cancel the 8821 for your old accountant.

Line 6, signature. If you file by mail or fax, you must handwrite your signature. Electronic or typed signatures are accepted only for forms submitted online. For businesses, the instructions explain who may sign: for example, an officer with authority to bind a corporation, or for a partnership, a person who was a member during the period covered.

The 120-day rule

One timing rule applies to Form 8821 specifically. If you submit it to authorize disclosure for a purpose other than addressing or resolving a tax matter with the IRS, for example income verification for a lender, the IRS must receive the form within 120 days of your signature date. The 120-day requirement does not apply when the purpose is assistance with a tax matter with the IRS.

How to submit it

The instructions list three ways when line 4 is not checked:

• Online at IRS.gov/Submit8821, using a Secure Access account,
• Fax to the number in the Where To File chart for your state,
• Mail to the address in the same chart.

Forms signed electronically must be submitted online. The IRS also offers its Tax Pro Account, which it says gives real-time processing for individual POA and TIA requests, and which anyone can use to request a TIA. See submitting Forms 2848 and 8821 online.

What your designee can do with it

Once recorded, your designee can call the IRS and ask about your account for the listed matters and periods, receive copies of notices if you checked the box, and, according to the instructions, get online tax information through IRS e-Services. That makes Form 8821 the standard tool for a professional who needs to pull transcripts before giving you advice.

What your designee may do with your information

The September 2021 instructions added a note that matters to both sides. Section 6103(c) limits the disclosure and use of return information received under your consent, and holds the recipient subject to penalties, brought by private right of action, for unauthorized access, other use or redisclosure without your express permission or request. In plain terms, your designee is supposed to use your information for the purpose you gave it, and nothing else. Choose designees you trust, and say in writing what the information is for.

When to use Form 8821

• Your accountant needs to see your transcripts and notices.
• A family member is helping you keep track of an IRS balance.
• A bookkeeper monitors payroll tax deposits for your business.
• You want someone to receive copies of IRS notices so nothing slips through.

When to use something else:

• Someone needs to argue with the IRS, sign agreements, or appear for you: Form 2848.
• Someone just needs to help on one phone call while you are on the line: oral consent may be enough. See third party designees and oral disclosure consent.

A practical example

Suppose your bookkeeper monitors your IRS balance for 2023 through 2025 and wants copies of notices. Line 1 is your information. Line 2 is the bookkeeper's name, address and CAF number, with the notice-copy box checked. Line 3 reads "Income, 1040, 2023 through 2025," with "not applicable" in column (d). Line 4 is blank. On line 5, if your outside CPA already has a Form 8821 you want to keep, you check the box and attach a copy of it. You sign and date. That is a complete, narrow, useful authorization.

Cleaning up later

Authorizations outlive relationships. When you stop working with a designee, revoke the authorization. The process is in revoking a power of attorney or tax information authorization. Your tax information is confidential by law. Form 8821 is how you decide who else gets to see it, and revocation is how you take that back.