Submitting Forms 2848 and 8821 Online, and How Tax Pro Account Works

For years, getting a power of attorney on file meant a fax machine, a cover sheet, and a lot of waiting. The IRS now offers two online routes. One is an upload of the familiar paper forms. The other is an all-digital request through Tax Pro Account that the taxpayer approves in his or her own IRS online account. They work differently, and choosing the right one saves time.

Route one: upload the form at IRS.gov/Submit2848 or Submit8821

This is the online version of faxing. You fill out Form 2848 or Form 8821, have everyone sign, and upload it through a secure IRS page.

What you need. The instructions for both forms say you need a Secure Access account to submit online. The IRS's submission page lists the steps: sign in or create an account, answer a few questions about the form, upload the form, and receive an email confirmation that it was received.

Rules the IRS lists for uploads:

• One form at a time, even for married couples filing jointly. Each form is linked to the taxpayer identification number entered. If you submit more than one form in a single upload, the IRS says the others will not be processed and it will mail a rejection letter.
• Attachments go in the same file as the form.
• Accepted formats are PDF, JPG or GIF, with a 15 MB size limit.
• More than two designees on Form 8821: check the box on line 2, create an attachment listing the designees, and save it with the form as one file.
• Do not double submit. If you already faxed or mailed a form, do not also submit it online.

After you submit. The IRS says you will get an email when the form is successfully submitted, but it does not notify you when the form is processed. It processes forms in the order received, regardless of whether they came online, by fax or by mail, and provides a page to check processing status.

Electronic signatures

Online submission is what makes electronic signatures possible. The form instructions say Forms 2848 and 8821 with an electronic signature image or digitized image of a handwritten signature may only be submitted online. Acceptable methods listed in the instructions include:

• a typed name typed into the signature block,
• a scanned or digitized image of a handwritten signature attached to an electronic record,
• a handwritten signature input on an electronic signature pad,
• a handwritten signature, mark or command input on a display screen with a stylus, or
• a signature created using third-party software.

The flip side: the IRS says that for security reasons, forms mailed or faxed must have a "wet" ink signature. Electronic signatures are not accepted by fax or mail.

Identity checks for remote signing

When a taxpayer signs electronically in a remote transaction, meaning the person submitting the form is not physically present with the taxpayer, the submitter must authenticate the taxpayer's identity unless the submitter has personal knowledge of the taxpayer, such as through a prior business relationship or a family relationship.

For an individual, the steps in the instructions and on the IRS page are:

1. Inspect a valid government-issued photo ID and compare the photo to the taxpayer through a self-taken picture or video conferencing.
2. Record the taxpayer's name, SSN or ITIN, address and date of birth.
3. Verify the name, address and SSN or ITIN through secondary documentation, such as a federal or state tax return, an IRS notice or letter, a Social Security card, or a credit card or utility statement.

For a business, the submitter must also confirm that the person signing has authority to sign for the entity, and verify the entity's name, EIN and address through documentation such as a W-2 or 1099, an IRS notice, or a utility statement. The IRS recommends keeping records of the documents used in each step.

Route two: Tax Pro Account

Tax Pro Account is the IRS's all-digital option. According to the IRS, it offers real-time processing of power of attorney and tax information authorization requests to individuals, withdrawal of authorizations, and one-stop access to taxpayer information and active authorizations.

Who can use it. The IRS says anyone can request a tax information authorization and view taxpayer information with Tax Pro Account. To request a power of attorney, the user must have authority to practice before the IRS as an attorney, CPA, enrolled agent, enrolled actuary or enrolled retirement plan agent.

Which taxpayers it works for. Requests go to individual taxpayers who have an address in a U.S. state or the District of Columbia and the ability to access an IRS online account. The taxpayer address entered must match IRS records. The practitioner can submit the request before the taxpayer creates an online account. Once the taxpayer signs in, he or she can view and approve the request under Authorizations.

What it covers. For calendar year filers, the IRS says requests can cover periods from the last 20 years through the current year plus 3 future years, with exceptions noted, for matters including Form 1040 income tax, split spousal assessments and innocent spouse relief under Form 8857, shared responsibility payments, and civil penalties limited to certain quarter-end periods.

One important side effect. Prior authorizations on file for the same tax matters, periods and authorization types will be revoked. To keep a prior authorization, the IRS says to use Form 2848 or 8821 instead, check the retention box and attach a copy of the authorization to keep.

Hours. The IRS lists Tax Pro Account availability as Monday 6 a.m. Eastern to Saturday 9 p.m. Eastern, and Sunday 10 a.m. to midnight Eastern, with occasional maintenance.

What the taxpayer sees

From the taxpayer's side, a Tax Pro Account request is simple. The request appears under Authorizations in the taxpayer's IRS online account. The taxpayer reviews who is asking, what kind of authority, and for which tax matters and years, then approves and electronically signs, or does nothing. Read the years and matters before approving. You are granting access to confidential information, and for a power of attorney, the authority to act for you. If anything looks broader than the job you hired the person to do, ask before you approve.

Which route should you use?

• Individual taxpayer, U.S. address, representative is an attorney, CPA or EA, and no prior authorizations to keep: Tax Pro Account is usually fastest. The taxpayer approves the request in his or her online account. See your IRS online account.
• Business taxpayer, or a taxpayer abroad: upload or fax the paper form.
• You want to keep an existing authorization on file: paper form with the retention box checked, submitted by upload, fax or mail.
• Specific-use authorization under line 4: mail or fax it to the IRS office handling the matter, not through the general upload.
• Need to talk to the IRS today and the form is not processed yet: the IRS says you can fax the form, with a wet ink signature, to the IRS employee handling the matter, or contact the Practitioner Priority Service.

Withdrawing and revoking online

The IRS's submission page says you can submit forms to revoke or withdraw authorizations. Taxpayers revoke by writing "REVOKE" across the top and signing and dating; representatives withdraw by writing "WITHDRAW" across the top of the first page and signing and dating. Practitioners can also withdraw without forms in Tax Pro Account. The full process is in revoking a power of attorney.

Common reasons online submissions fail

The IRS maintains its own list of common rejection reasons, and the patterns match paper filings: missing tax matters or periods on line 3, general references such as "all years," missing signatures, electronic signatures on forms sent by fax or mail, and multiple forms bundled into one upload. Read Form 2848 line by line or Form 8821 explained before you hit submit.

The technology changed. The rules did not. A clean, specific, properly signed form still gets recorded fastest, whichever door you use.