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.
Shelly is a Managing Director in BMO Capital Markets where she leads a global team responsible for the first line of defense including Trade Floor Supervision, Business Unit Compliance, AML Operational Risk & Resilience, Crisis Management, Algorithm & Automation Risk, and ESG Risk. The mandate includes preventing loss due to failure in process, people and systems and ensuring the execution of trading and investment banking businesses in compliance with applicable regulations.
In addition, she is focused on integrating data with machine learning and AI to enhance the way we work and make decisions and to focus on real versus perceived risk. She leverages similar technology applied in a different way to design process and organizational efficiencies, influencing across the organization.
Previously, Shelly was the COO for BMO's US Trading business. She has over 25 years of experience across industries. Prior to joining BMO, she was a global COO at Barclays. She has a unique blend of experience in sell-side M&A, corporate infrastructure, risk and in leading large scale regulatory and business transformations.
Shelly earned an MBA from Columbia Business School, an MS from Johns Hopkins University, and a BS from Penn State University. She holds FINRA Series 7 and 63 licenses. She has regulated and non-profit board experience and currently sits on the board of BMO Europe PLC and BMO Harris Investment Co.
She enjoys hiking, fishing, singing, playing guitar and sports.
Deb Franklin is the co-CEO of PEAK6 InsurTech, the insurance operations and technology subsidiary of PEAK6. PEAK6 uses technology to find a better way of doing things. The company’s first tech-based solution was developed in 1997 to optimize options trading and, over the past two decades, the same formula has been used across a range of industries, asset classes and business stages to consistently deliver superior results. Today, PEAK6 seeks transformational opportunities to provide capital and strategic support to entrepreneurs and forward-thinking businesses, helping to unlock potential and activate what is into what ought to be.
Eric Rosenbloom, CLTC, ChFC®, is Vice President, Wealth Services at Alera Group Wealth Services. For over 30 years, he has counseled individuals, families and businesses about long-term care and how to create and implement customized financial strategies to help enhance and protect their financial security.
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.
