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.
Dave Sikora is a technology industry veteran with more than 20 years of experience that spans enterprise software, data intelligence, private equity, mobile applications and supply chain solutions. As chief executive officer at ALTR, he is focused on expanding the ways enterprise companies can leverage blockchain technology to reduce threats to data integrity. He holds an MBA from Harvard Business School and serves as a strategic advisor to startups in the Austin tech market.
Martin Fiore is EY Americas vice chair of tax.
Brendan Miller is a principal analyst at Forrester Researching, serving digital business professionals. His research focuses on retail digital transformation, consumer insights, payments, and eCommerce trends in the age of the customer. Brendan has specific expertise in helping retail leaders understand the opportunity derived from payments as well as the vendors that facilitate the delivery of leading digital experiences. His interests include emerging digital payments, rebuilding checkout experiences for our mobile world, retailer security and risk challenges, and insights into the state of the digital shopper.
Brendan’s research and analysis have been widely cited in publications including The New York Times, USA Today, Bloomberg, Fortune, Barron’s, CNBC, as well as NPR, The Los Angeles Times, and Financial Times.
Previous Work Experience
Prior to Forrester, Brendan spent 20 years as a B2C and B2B marketer, spanning technology, services, retail, CPG, and durable goods. Most recently, he led product marketing duties at payment firms, such as First Data, Mercury, and Vantiv. Prior to working in payments, he held B2C marketing leadership roles at Pulte Group and Graham Advertising (a leading automotive advertising agency), and he was also a managing director of a market research and strategy firm.
Education
Brendan holds a BBA in marketing/management from Northwood University in Midland, Michigan, as well as an MBA from the University of Denver, Daniels College of Business.
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.
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.
