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.
Leslie C. Egiziano, MBA, SHRM-SCP, SPHR, is a human resources consultant at Paychex HR Services. She has over 15 years of experience working with Paychex clients in HR Solutions. She came to the company with a diverse work history which helps her connect with a variety of clients. She’s done everything from sales and marketing to establishing an HR department and hiring over 400 staff in a year and a half for a tech startup company — all while continuing her education and certification programs.
Mitch Ocampo is Managing Director and Head of Innovation for RGAX Americas. As the transformation engine of Reinsurance Group of America, Incorporated (RGA) he is focused both on the innovation strategy of RGAX Americas and expanding its capabilities in emerging solutions to better serve clients and solve large-scale industry challenges.
An experienced technology executive, Mitch’s work over the past two decades has taken him to the cutting edge of reinsurance and financial services innovation technology. Since 2015, his primary focus has been insurtech: starting in 2015, he was Chief Technology Officer for reinsurance technology specialist TAI (Tindall Associates), and then, after TAI’s acquisition by LOGiQ3, was Group Chief Technology Officer for LOGiQ3’s companies, which include TAI, APEXA, and Cookhouse Lab. LOGiQ3 was acquired by RGAX in 2017.
Previously, Mitch spent four years as Managing Director, Strategic Industries, Americas, for msg global solutions, a global strategic consulting and intelligent IT solutions specialist. Before then, he was Partner and Managing Director of Kogent Corporation, which builds custom business intelligence, data warehousing and analytics solutions for clients. He has also worked in data solutions and software development/engineering roles for a variety of companies including IBM, EMC, and Thomson Reuters.
Mitch’s Bachelor of Arts (B.A.) is from the University of New Hampshire in Durham, N.H. (U.S.), and holds a dual-degree joint M.B.A. in international business from Brown University, Providence, R.I. (U.S.) and IE Business School, Madrid, Spain.
An active member of the global innovation community, he serves on the advisory board of numerous startups and is a mentor, coach, and advisor to Brown University’s B-Lab accelerator, supporting entrepreneurs developing high impact ventures.
Marc Laliberte is senior security analyst at WatchGuard Technologies.
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.
