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.
Fatemeh Khatibloo is a principal analyst at Forrester Research. Fatemeh serves B2C marketing professionals, with a focus on the shifting global consumer data ecosystem. She helps marketers navigate the complex connections between privacy, trust, and ethical data use, including the practices and vendors that can help them bridge the privacy/personalization paradox. Her seminal research on personal identity management (PIDM) describes how consumers will soon manage the sharing of their personal data with each other and with businesses. Her report "Adaptive Intelligence" further defines a framework for privacy-compliant data sharing between organizations to gain insight, reduce risk, and increase profitability.
Fatemeh focuses on privacy, identity, customer insights (CI) services, CI strategy, data monetization, data sharing, adaptive intelligence and consumer preference.
Previous Work Experience
Prior to joining Forrester, Fatemeh was principal of Times Two Marketing, where she built social and multichannel marketing programs designed to engage consumers, drive brand loyalty, and deliver relevant, actionable data to her clients. Prior experience at Binger Catalog Marketing, Abacus, and HagginGroup (now Epsilon) provided her with a deep understanding of the challenges and opportunities facing multichannel organizations across a spectrum of channels, market verticals, and disciplines. She has also held multichannel marketing positions on the client side, with firms like The Flax Companies and The Sharper Image.
Fatemeh is a member of the International Associate of Privacy Professional (IAPP) and is a Certified Information Privacy Manager (CIPM). She has served as a judge for the Multichannel Merchant Awards and the ECHO Awards.
Education
Fatemeh studied journalism at The George Washington University.
Mr. Allburn is a 20+ year industry veteran and President/CEO of DataDelta, Inc. which provides CDI-MDM consulting and patent-pending, vendor-neutral match accuracy analysis software used to analyze & optimize the match accuracy of Data Quality, CDI & MDM vendor match engines including custom, in-house match engines. Mr. Allburn has held senior technical and strategic management positions in the fields of Database Marketing, Data Quality, CDI and MDM for industry leading companies such as Metromail / Experian, the IBM TJ Watson Research Center, Firstlogic and Group 1 Software. During his career Mr. Allburn has been responsible for over 200 successful CDI projects in banking, telecom, catalog and other industries. He is an international speaker and instructor for CDI-MDM Workshops, a contributor to DM Review and other publications, and a recognized Expert Witness in the Data Quality and CDI-MDM industries.
Jim Kane is director at Information Services Group, a leading global technology research and advisory firm.
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.
