Anna Falkenstein: All right, I see it's the top of the hour. For those of you just joining,
welcome to today's webinar, "Uploading Forms 2848, 8821 with Electronic Signatures." We're glad
that you're joining us today. My name is Anna Falkenstein, and I am a Stakeholder Liaison with
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Before we move along with the session, let me make sure you're in the right place. Today, we will
share information related to uploading Forms 2848 and 8821 with electronic signatures. This
webinar is scheduled for approximately 60 minutes. Let me introduce today speakers. Sharyn Fisk
is the Director of IRS Office of Professional Responsibility, OPR. As Director, she is
responsible for the IRS oversight of tax professionals, who practice before the IRS is set out in
Treasury Circular 230. Andrew Chiu is a Director of Product Management and User Experience in
the IRS Office of Online Services. In this role, he is responsible for providing leadership,
oversight and direction for the strategic growth of IRS online products and services. Now, I'll
turn it over to Sharyn to begin our presentation. Sharyn? Sharyn Fisk: Thank you very much.
Right, so in today's presentation, we have several objectives that we aim to meet. One is to
understand the new options for submitting third-party authorization forms that has been signed
electronically. We're going to review the step-by-step process for a successful uploading of
these third-party authorization forms and learn what electronic signatures are acceptable. And
then understand the ways to authenticate the taxpayer's identity, when there has been an
electronic signature done in a remote transaction. We'll define remote transaction too, right. So
let's start with a little background on why we created this new option for submitting third-party
authorization forms that have electronic signatures. As you all recall, in July of 2019,
Congress enacted the Taxpayers First Act, the TFA. And this act had approximately 45 legislative
provisions. Now, the goal of all those provisions was to modernize and improve the IRS with
respect to the services organization and operations, and its technological capability. The TFA
goal we're addressing here is TFA 2302. Section 2302, the TFA requires the IRS to establish
uniform standards and procedures for the acceptance of taxpayer signatures appearing in
electronic form regarding any request for the disclosure of the taxpayers return or return
information to a practitioner. And typically this is done through the Form 8821, right, the Tax
Information Authorization. And also with respect to any Power of Attorney granted by a taxpayer
to a practitioner, and that's our Form 2848, the Power of Attorney. The Office of Professional
Responsibility has taken the lead on implementing the IRS's respond to provision 2302. The OPR is
working towards meeting provision 2302 in 2 ways. First, by creating a cross functional team
within the IRS to develop a mechanism for submitting Forms 2848 and 8821 that have electronic
signatures through the Taxpayer Digital Communication, the TDC platform. And that is set to be
released in January of 2021. This process will allow authorization forms to be signed and
socially distant transaction that's our remote transaction, as COVID is continuing to affect us
on our taxpayers and our tax professionals. These forms can be signed and submitted to the IRS
without the taxpayer or the tax professional leaving their home. And the signature can be
obtained without the need for certain equipment like scanners, fax machines or the need to have
an eFax service. Now the IRS is also working with a cross functional group within the IRS on the
creation of the tax professional accounts platform. And this will allow for the creation of
online authorization and this platform is set to be released in July of 2021. TFA provision 2302
states that no later than 6 months after the date of enactment, the secretary shall publish
guidance to establish uniform standards and procedures for the acceptance of taxpayers'
electronic signatures on the Forms 2848 and 8821. Now within that 6-month deadline, on December 3,
2019, the IRS published an overarching e-signature policy, and if you're looking for that,
that's in IRM 10.10.1. This IRM addresses electronic signature policy for all IRS forms, unless a
form is explicitly excluded. Now, because e-signatures or electronic signatures were not
accepted on Forms 2848 and 8821 at the time this IRM was issued, the IRM didn't specifically
cover these 2 forms. And so, this TD solution as well as the tax pro account aims to address
that gap. In January 21, the IRS is going to launch the "Submit IRS Forms 2848 and 8821 Online".
Now, this is a special IRS.gov webpage featuring IRS Secure Messaging platform. So, allow for the
upload of signed Forms 2848 and 8821. To access the Secure Messaging platform, an individual
must verify their identity through Secure Access, or use their existing Secure Access username
and platform - excuse me password. This Secure Messaging platform will require the individual to
answer a few questions to be anywhere from 3 to 5 questions depending on the type of signature
that's on that particular form. And we'll explain that a little later on. Checkboxes verifying
their clients' identity has been authenticated, when that form is signed electronically by the
taxpayer in a remote transaction. And again, we'll clarify this, a little later on in this
presentation. And then we're going to upload that signed authorization form and hit the "Submit"
button. Under this new online submission platform, taxpayers and tax professionals have the
option of using commercial digital signature products to electronically sign a Form 2848 or 8821.
So there's no particular signature technology required. Now, the instructions to both these forms
will contain the explanations and the requirements for those electronic signatures which also
includes, how you go about verifying the taxpayer's identity, when the taxpayer has
electronically signed a form in a remote transaction. Now, a remote transaction is one where the
taxpayer has signed the form not in the presence of the tax professional, right. So you've gotten
a signed form from the taxpayer, but it's within an electronic signature attached to it and they
send it to you by e-mail, or they fax it to you, or they mailed it off to you in the mail. These
authorization forms can be submitted to the IRS either in a PDF or some other image format
through that submit Forms 2848 and 8821 online platform. Authorization forms that come through
this online platform are going to be routed to the CAF Unit and processed just like other
authorization forms that the CAF Unit received via fax or mail. They will be processed in the
same manner, as those that come in by fax and mail. In the summer of 2021, I mentioned, the IRS
will launch the new tax pro account - tax professional account. And this is a secure self-serve
online portal that will allow for the actual creation of online authorization that can be signed
by tax professional and taxpayers digital. Tax professionals will be able to access their tax
pro account by passing through Secure Access authentication, or again by using their existing IRS
account such as you may have an e-Services account, you have your username and password for
that. On the tax pro account, tax professionals will initiate the third-party authorization
through their account, which will then interface with their client's individual taxpayer account.
The authorization will be routed to the client's account for the client's digital signature.
Accessing their own online account, the taxpayer will digitally sign that authorization. And upon
that signature by the taxpayer, the authorization will be routed to the CAF unit automatically.
When using tax pro account to create these authorizations, the wait time for CAF processing is
minimized. Authentications will be processed almost immediately. Over time, the tax pro account
functionality is going to increase, so we're going to expand beyond just the creation of online
authorization, so looking forward to that. Now here is a diagram that kind of shows the proposed
process flow for obtaining clients' signatures and uploading it to the IRS to submit 2848 and
8021 online. The first step, our client is going to sign the authorization form. They can either
do that in ink or sign it electronically. The tax professional is going to authenticate the
taxpayer's identity. And again, we'll go into more detail on that. And at the form of 2848, the
tax professional is going to sign the document as well, either in ink or electronically. If you
recall, the 8821 only has a signature line for the taxpayer. Next, the tax professional is going
to go to this special IRS.gov web page called "Submit Forms 2848, 8821 Online," and access the
tool with their Secure Access username and password. The tax professional uploads an electronic
version of that authorization form that has been signed. The CAF unit is going to receive that
authorization form. They're going to review it for completeness and accuracy, right, just like
they do with everything we mail in or fax in. And if the form is complete, and the information is
verified, the CAF unit will process the form. Now, forms received online are going to be
processed along with the forms received by mail and fax, which means on a first-come first-served
basis. So these forms will not have expedited processing. So it will just have the same
processing as the other authorization forms that come in to the CAF unit. All right, Anna, let's
take a moment and have our first polling question. Anna Falkenstein: All right, that sounds good
to me. Audience, our first polling question is, "The new Submit Forms 2848 and 8821 online
process will allow you to: A, upload authorization forms with either electronic signatures or wet
signatures to the CAF unit for normal processing; B, offer a safe remote transaction that
protects you and your client from possible COVID exposure; C, obtain immediate approval and
bypass CAF processing; or D, both A and B." Take a moment and click on the radio button that best
answers the question. I'll give you just a few more seconds to make your selection. Okay, I
think we can go ahead and stop the polling now. And let's go ahead and share the correct answer
on the next slide. And the correct response is D, both A and B. And looks like, waiting on the
response here. Sharyn Fisk: Pins and needles, pins and needles. Anna Falkenstein: It's coming.
85%, okay, so 85% of you got it right. And that's awesome. So keep listening closely. And I
believe, Andrew, you're up next. Andrew Chin: Yes, I am. Thank you very much, Anna. What you're
seeing in front of you is the tax professionals' webpage on IRS.gov, which I believe most of you
are probably familiar with. Before I begin, a couple of things I want to mention. You're going
to be seeing several, "Under Construction" drafts of web-pages and process flows. But I want to
emphasize, take the opportunity to emphasize that these are still drafts. We have held several
customer feedback sessions. And we are already making changes to these drafts. But they weren't
able to be available for this session. I will be going over some of those changes. But I would
ask that you focus on the high points that Sharyn mentioned earlier. There will be some
interactive aspects to help with the workflow. And ultimately, this will enable all of you to
upload electronically signed 2848s and 8821s or other scanned forms such as revocations, as
Sharyn described. Getting into this page, I would like to take the chance to point out that there
will be a link, actually several, on the tax professional landing page. You'll see the first one
on the lower left navigation at the bottom, entitled "Submit Forms 2848 and 8821 online." You'll
also see a similar link under the call-out box for "Serve Your Clients." These links and others
will be on many IRS.gov pages. And we will also have several friendly URLs available for your
bookmarking needs. Regardless of which link or bookmark you use, you will ultimately be taken to
a landing page very similar to this one. This page will provide you with the basic instructions,
what to get started, how to submit the form, what to expect after you submit. Of course, you're
welcome to just click the "Login to Submit" button and begin. Once you've clicked that button,
you'll be taken to Secure Access, where you will need a Secure Access account as Sharyn
mentioned earlier. I'm not going to go into the registration process in depth here. But if you
don't have one, feel free to use the "Create Account" button on the left to begin that process.
If you already have one, feel free to log in as you normally do. And of course, if you have any
e-services account, you should be aware that you are already signed up. Once you've begin the
log-in process, you'll need to sign in just like any other Secure Access logging in. We will send
you a SMS code or you can use your code generator on IRS2Go app. Once you successfully
authenticated, you'll be presented one time with the terms of service for Taxpayer Digital
Communication. This is the platform we are using to host the service. And you will need to agree
to the terms of service. We don't anticipate making changes to these often. However, if we were
to do so, you would be presented with these again in the future. Once you've accepted the terms
of service one time, we'll need some basic information from you to make sure we can route your
form to the right place. The questions that you'll be seeing on this screen, and the next few are
just examples. The precise wording may and probably will be different in January when this
launches. To begin, you'll need to tell us what type of form you'd like to submit. As mentioned,
this allows for the submission of Forms 2848, 8821, and Revocations and Withdrawals, both
electronically signed and wet signatures. You'll need to attest that you've authenticated the
taxpayer. And we'll have more information coming later in this webinar. We'll be adding some
additional information to this screen to make sure everyone understands what this means. And
Sharyn will again be discussing that a little bit later. Notice on the right-hand side that the
questions you've already answered through this Guide Me process are pre-populated on the right
along with the answers you can check as you go if necessary. Again, I do want to mention that the
steps in this platform and process are under construction and a work in progress. This
particular question will likely be removed once this goes live in January, based on the fantastic
feedback and engagement from your colleagues who participated in our focus groups. We, of
course, have the IRS very much appreciate their efforts to provide feedback and help us
continually improve our online services. If you're going to mail or fax your form, you do need to
send it to a specific location based on the type of form. And that's exactly what we're doing
here as well and replicating that part of the routing process, domestic, international or tax
clinic. We'll need that same information to make sure it gets to the right place for processing,
as Sharyn mentioned earlier. Finally, you're almost ready to submit. There will be some basic
instructions on the top of this page, we will ask you to provide the SSN, EIN or ITIN to help us
with the forms processing. We will also be asking and confirming whether or not an electronic
signature was used. Continuing on, this particular screen, we've shown in 2 different slides just
to make sure it's readable. You'll notice at the bottom, there is an attached file link, and the
submit button. Once you've completed answering those questions, you can go ahead and click on the
attach file. The process is just the same as most other upload processes you may be used to in
your private life, a window will pop up on your computer, and you'll be able to select the file
in question and click "Open" is transmitted to us. At this point in time, you want to make sure
you select the correct version. So you may need to adjust your team or office workflow to make
sure you're uploading the correct and final version to the Internal Revenue Service. Once that
file is ready, you'll notice, you're taken back to this screen and under the attachment section
that file is now listed just like it would be on many other platforms, again, that you may use
in your personal life. You can upload only one form at a time. If you do upload more than one,
they won't be processed. Doing so helps us expedite the processing within the CAF Unit and
maintain the processing pipeline. Once you're ready, you can go ahead and click the "Submit"
button. And you'll be taken to this confirmation page again under construction. This confirmation
page will allow you to recognize that the form was submitted to us successfully, you will also
receive an e-mail confirmation. The e-mail for those of you who are concerned does not include
PII or any other identifying information. But it is a confirmation that we did actually receive
your form as well. I would also like to point out here that if you're done, feel free to click on
the "Exit" button and terminate your session. You can if you have additional forms, click the
"Submit" another form button and that will start the workflow all over again. As shown, you'll
be taken to the beginning, where you'll need to answer the same basic routing questions again to
help get that new form to the right location in the CAF. As long as your session is active, you
won't have to log in through Secure Access time to time again, just wash, rinse and repeat on
these questions in workflow. Anna, how about another polling question? Anna Falkenstein: Okay,
I'm ready. Audience I hope you're ready. So here's our second polling question. The new upload
tool will allow tax professionals do: A, upload tax returns; B, ask questions of the CAF Unit;
C, upload authorization forms and withdrawal requests; D, transmit an amended return. Okay. So
take a moment to review the question and click the "Radio" button that best answers that
question. I'll give you just a few more seconds to make your selection. Okay, let's go ahead and
stop the polling now and share the correct answer on the next slide. And the correct response is
C, upload authorization forms and withdrawal requests. And let's check on the number of correct -
for percentage of correct answers. All right. You all were definitely listening. It was 97%.
That's awesome. Excellent. Okay, Sharyn, I'll turn it back to you now. Sharyn Fisk: Thank you,
Anna. All right. So with the addition of this online submission platform in January of 2021,
there are now going to be 3 ways that you can file your authorization forms with the IRS. If the
authorization form that's the 2848 or the 8821 has a handwritten signature, a wet signature,
right. The authorization form can be mailed, faxed, or submitted online to the IRS. Now, if that
authorization form has an electronic signature on it, right, a DocuSign and Adobe signature,
somebody typed their name in the signature block, then that authorization form may only be
submitted via the online platform. And there's a reason for that and we'll get into that. Now, if
an authorization form that reflects an electronic signature is sent to the IRS, by mail or by
fax, and that does include faxing to the Practitioner Priority Service, right, the PPS, it is
going to be rejected as not processable. Again, if you fax your authorization form, and it has an
electronic signature on it, or you mail it, it's going to be rejected as not processable. If you
need immediate assistance with respect to a client or immediate access to taxpayer information,
or you intend to use the PPS line, get a wet signature on that authorization form. Now, when
summer of 2021 rolls around, we're going to have the addition of a tax pro account, then there
will be 4 ways in which to submit third-party authorizations to the IRS. Submitting a Form 2848
or 8821, by mail, facsimile or online, depending on what kind of signature is on that form, or
creating an online authorization on the tax pro account that will have a digitally signed - be
digitally signed by the taxpayer and the tax professional. So let's chat a little bit about what
it means to have an electronic signature, because we've used the term electronic signature and
we may also hear the term digital signature. So an electronic signature can appear in many forms,
it created by many technologies, no specific technology is required. An example of an electronic
signature might include typing the name in the signature box of the form, right, or scanning and
digitizing an image of a handwritten signature, a fax, a handwritten signature that's been put
into an electronic signature pad, or a handwritten signature that was put on a display screen
with a stylus. So what is that difference between an electronic signature and a digital
signature? An electronic signature is an electronic symbol attached to an electronic record used
by a person with the intent to sign a document. As explained on the prior slide and I gave those
examples of electronic signatures such as typing your name in the signature box of the form. The
online submission platform is a mean to accept images of electronic signatures. A digital
signature is a type of electronic signature, but a digital signature has encrypted data attached
to it. Tax professionals and taxpayers will digitally sign online authorizations on the tax pro
account when it launches next summer. Let's see, if I've read that clear enough. And we have a
polling question here, Anna? Anna Falkenstein: I think we do. Okay, audience, this is our third
polling question. Examples of acceptable electronic signature methods include: A, a typed name
that is typed into a signature block; B, a scanned or digitized image of a handwritten signature
that is attached to an electronic record; C, a handwritten signature input onto an electronic
signature pad; D, a handwritten signature mark or other command input on a display screen with a
stylus device; or E, all of the above. All right. Let's take a moment to review the question and
click the "Radio" button that best answers the question. I'll give you just a few more seconds
to make that selection. Okay. Let's go ahead and stop the polling now and share the correct
answer on the next slide. And the correct answer is E, all of the above. And let's check on the
percentage of correct answers. Wow, you guys are doing great, 97% again, awesome. Sharyn, let's
just keep rolling. Sharyn Fisk: Excellent. All right, so earlier we mentioned that if a
taxpayer electronically signs the authorization form in a remote transaction, the taxpayer's
identity must be authenticated. Let's chat about authentication. A remote transaction is one in
which the taxpayer has electronically signed the authorization form, not in the presence of the
individual who's submitting the form to the IRS. So if, say, your client signed a form
electronically and sent it to you, this is a new client, how do you know the person who's
submitting the form to you, who claims to be the taxpayer is actually the taxpayer? We all know
there's unscrupulous individuals out there attempting to steal people's Personally Identifiable
Information, right, your PII. These individuals are not above impersonating taxpayers to obtain
additional PII to participate in stolen identity refund fraud or other fraudulent acts. And these
individuals are also not above using an unsuspecting tax professional to assist unknowingly in
committing fraud. So to reduce the risk to the IRS and reduce the risk to you, taxpayers through
electronically signed authorization forms in remote transaction must be authenticated. Now, if
you already know the taxpayer that you have a prior business relationship, right, you've been
doing this person's tax returns for 30 years or the person has hired you for an audit, then
you're adding another year to the POA, or you have a personal relationship with the taxpayer.
It's a friend or colleague or family member, then authentication at this time is not necessary.
You already authenticated the taxpayer. As I mentioned, authentication has been done. All right.
Now, authenticating a taxpayer's identity is something that you probably already do under your
Due Diligence as to Accuracy requirement, under Section 10.22, of Circular 230, right, that's
Due Diligence as to Accuracy in the preparing or assisting in the preparation of or proving or
filing documents related to IRS matters, and also in ensuring the correctness of oral and written
representations made by you, the practitioner to the IRS. But this is not just a Circular 230
issue, it's also about penalty protection. It's also an E&O issue. You want to make sure that
you are dealing with the individual who claims to be the taxpayer is actually the taxpayer. You
want to be able to show you've exercised that due diligence. You want to be able to show that
the taxpayer - who the taxpayer is and what they have signed or what they have not signed. When a
document is hand-signed, you can point to that signature being out of the taxpayer, right, it
matches the signature on their driver's license or it matches the previously filed return. But
when we have an electronic signature, you don't have that same ability of matching that same
option of proof, so an extra authentication step is necessary. Now, a lot of you probably already
have standard business procedures in place, like requesting IDs from new clients, or requesting
IDs every year from the same client to authenticate a taxpayer. You want to make sure, because
you want to make sure you know who you're dealing with, and what you're making - what
representations you're making to the IRS when you are filing and submitting documents for the
service. The IRS is proposing changes to the instructions of both the Form 2848 and the 8821 to
explain what it means to authenticate the taxpayer's identity, when an authorization form is
electronically signed in a remote transaction. So to authenticate the taxpayer's identity, that
an individual submitting the authorization form to the IRS via this online platform must, first,
inspect a valid government photo identification and compare the photo to the taxpayer. Now, this
comparison can be done by the taxpayer taking a selfie and sending it to the tax professional or
perhaps you and your new client have had a video conference, right, you met on Zoom or FaceTime.
After inspecting the taxpayer's valid government ID, you're going to record the name, Tax
Identification Number, address, and date of birth of the taxpayer. Now, because we're talking
about authorization forms, right, we're talking about the 2848 and 8821, these forms already
require us to record the taxpayer's name, Tax Identification Number and address. So really the
only additional information we're seeking to have recorded here is the taxpayer's date of birth,
if that's applicable, right? If we're talking about an entity, they don't have a date of birth.
So the actual recordation of this information is the 2848 or the 8821 itself, perhaps with a
notation on the side, if we're dealing with an individual about what that individual's date of
birth is. Put a little note on the copy of that authorization form you're keeping in your file.
Next, we want to verify the recorded information through secondary documentation. So, we can do -
we can verify the taxpayer's name and address, and Tax Identification Number, and date of birth,
if it's applicable, through a couple of different secondary documents. It's hard to find one
document that's going to have all of that information, right. So, for example, if you have a new
client that's come in, they've given you their photo ID or their government ID, but they've
changed their address since they've gotten their driver's license. They can bring to you -
besides the photo ID, they can bring to you, say a 2019 W-2 to verify their names, and their Tax
Identification Number. And then, also bring or provide you with a recent utility statement that
can verify their new address. Now, if all of this authentication process sounds familiar, it's
because - it's, there are similar requirements outlined in Publication 1345, regarding the
electronic signatures on electronically filed Forms 1040. So again, this authentication process
is for taxpayers, who are unknown to you, who have signed that authorization form electronically
in a remote transaction. To use the Submit 2848 and 8821 Online platform, an individual has to
register for Secure Access. And some of you, hopefully many of you are already are familiar with
and registered for Secure Access, having used one of the IRS' e-Services such as online tool for
tax professionals or other similar online tools, for example, the e-Services online transcript
delivery service or system. If you are not already registered for Secure Access, you'll need to
do so if you are interested or intend to submit authorization forms via this Submit Forms 2848
and 8821 Online platform. To register for Secure Access you're going to need personal
information and the mailing address on your most recently filed return, financial account
information and a U.S.-based cell-phone registered in your name to receive a onetime activation
code. Now, you can opt to receive your activation code by mail, if you don't have a cell phone or
your cell phone may be registered in the name of a business, so that they're able to handle that
problem. There is a virtual assist also on the IRS webpage to help you with Secure Access. And if
you do want to submit your authorization forms online and you want the option of obtaining
electronic signatures on these forms, register for Secure Access now, because this registration
process does take a bit of time to complete. Now, if you have more - you want more information on
Secure Access and registration, you can go to www.irs.gov/SecureAccess. And again, there is a
virtual assistant to help if you have questions on registration. All right, Anna, do we have time
for another polling question? Anna Falkenstein: We sure do. Audience, this is our fourth and
final polling question. Here's the question. I am responsible for authenticating the identity of
a client I do not know by: A, matching a government ID to a selfie or video conference; B,
recording the name, SSN or ITIN, address and date of birth of the client and matching that
information with other documents such as a prior tax record or a Social Security card; C, options
A and B; or D, none of the above. Again, just take a quick look at that question, click on the
"Radio" button that best answers the question. I'll give you just a few more seconds to make your
selection. And let's go ahead and stop the polling now and share the correct answer on the next
slide. And the correct answer is C, both A and B. And now let us take a quick look at the
percentage of correct response is pulling up. It's an 83%, okay, not quite as good as that 97%
earlier, but pretty good. Sharyn, we'll send it back to you just briefly. Sharyn Fisk: All right,
83%, that's still a good grade. Anna Falkenstein: Yeah. Sharyn Fisk: All right. So instructions
for the Form 2848 and 8821 will identify the landing page, where you're going to be able to find
this platform, or the landing page for the submitting Forms 2848 and 8821 online. And those
revised instructions will be coming out in January. And as Andrew mentioned, this landing page
will provide information on how to submit the forms online. So in addition to the form
instructions, the landing page will have all the details that we need. All right, Anna, that's
all we have. So I'm going to hand it back over to you. Anna Falkenstein: Thank you, Sharyn.
Hello, everybody. It's me again, Anna Falkenstein, and I will be moderating the Q&A portion of
this session. Before we start the Q&A portion, I do want to thank everyone for attending today's
presentation, Uploading Forms 2848, 8821 with Electronic Signatures. Earlier, I mentioned we want
to know what questions you have for our presenters. And here is your opportunity. If you haven't
input a question yet, there is still time. Go ahead, click on that dropdown arrow next to the Ask
Question field and type in your question. One thing before we start, we may not have time to
answer all the questions submitted. However, let me assure you, we will answer as many as time
allow. If you're participating to earn a certificate and related continuing education credit, you
will qualify for one credit by participating in at least - for at least 50 minutes from the
official start time of the webinar, which means that the first few minutes of me chatting before
the top of the hour does not count towards that 50 minutes. So let's go ahead and get started, so
we can get to as many questions as possible. And I do see we've got quite a few questions here.
Let me scroll down. Here we go, oops. All right. I'm going to, let's see, you know what, we're
going to give Sharyn just a moment to catch her breath, because she was talking quite a bit
towards the end. We're going to ask Andrew the first question. Okay, Andrew, here's the first
question. "How do I know that what I'm submitting is going to the IRS is secure?" Remember to
take yourself off mute. Andrew Chin: Thank you, Anna. Anna Falkenstein: There you go. Andrew
Chin: Yes, thank you, Anna. That's a great question. So very quickly, TDC, the Taxpayer Digital
Communications program and platform follows all the Federal security standards as mandated by
the Office of Management and Budget, and all the guidance and instructions promulgated by the
National Institute of Standards and Technology, NIST, in their cybersecurity guidance and rules.
We also conduct annual cybersecurity audits with our IT organization to make sure that the
platform is meeting the required security practices. We also conduct other risk assessments to
make sure that it's meeting our requirements. And finally, I would just reassure everyone that as
a part of those requirements, the platform encrypts all the information according to federally
approved encryption standards from your submission all the way through the platform. You can rest
assure that the information is only being shared with the Internal Revenue Service. Thank you,
Anna. Anna Falkenstein: Okay, thank you. I'm going to ask you one more real quick before we give
one to Sharyn. What will we see or what kind of information can we expect to see in the
confirmation e-mail? Andrew Chin: That's another great question. So we're excited to be able to
provide the confirmation e-mail to you all. And as Sharyn noted before, at the IRS, we are very
concerned with privacy, disclosure, and in general, the authentication of the information. So we
want to make sure that we're protecting your taxpayers, because they're our taxpayers, and we're
protecting you as well. To that end, the e-mail will not contain any TINs or other taxpayer
information. As Sharyn mentioned, it won't contain any of that PII. But it will confirm that we
did receive the form for processing. So you can rest assure that that e-mail makes the way to
you over the Internet, and finally ends up on your system that no one else will be aware that, a
particular taxpayer now has a POA submitted with you. But it is a confirmation, in addition to
and supplementary to the confirmation you see on the screen once the upload has been completed.
Anna Falkenstein: Okay, all right. Sharyn, I'm going to throw the next question to you. And this
is a good question. "Why is this an improvement over the current system?" Sharyn Fisk: Very good
question. So, it is an improvement over the current system for several reasons. One, just dealing
right now with the environment that we are in, it allows us practitioners and taxpayers to get
that authorization in, in socially distant transactions, right. There's no need for the
practitioner to or the tax professional to create the form, print it out, sign it, scan it, send
it back to - send it to the client, the client may or may not have those print or scan
capabilities, so that they're going to need a printer. If they have a printer, they're going to
sign it, they don't have a scanner, they're going to have to go down to the post office and drop
this thing in the mail. This electronic signature process will avoid all of that, we don't need
scanners, we don't need printers, we don't need fax machines. And we can get all of this done
much faster at the front end than we could with a typical wet signature when there's not a
face-to-face interaction with the practitioner and the client. Anna Falkenstein: Okay, okay. And
I totally agree. Sharyn, I'm going to throw one more question at you since you're underlying
right now. The question says, I have two designees on the Form 8821. Can I still use this? What
do I do? Sharyn Fisk: Sure. Actually, one of the changes we made to the 8821 was to make a space
for an additional designee. So the new form will have spots for two, but let's say we have four
designees. You would still go through the same process, right, the taxpayer signs that form, and
there'll be a statement attached to that 8821, which can be additional designee, those two
pieces of paper will be scanned together as one 8821 Form. And then you'll go through the same
process through this online, you'll log in, you will answer a few questions, you'll have scanned
a copy of those two pages into one document and you will upload that one document and hit the
"Submit" button. So, it's - it's as if you would've fax those two pages to the IRS. Anna
Falkenstein: Okay. All right. Andrew, I'm going to throw another one at you now. Andrew Chin:
Sure. Anna Falkenstein: Good question. I think you sort of touched on this before, but go ahead,
let's expand on it. It says, why do I have to upload each form separately? Andrew Chin: Great.
Thank you for that question. We're asking that you upload each form separately to make sure that
we can optimize the workflow and CAF Unit processing as much as possible. As you know, when you
fax those or mail those in. They are processed one at a time and by keeping them separate. This
minimizes any additional work that the CAF Unit is going to have to do to just assemble the file
in order to process it. That's why we're asking for your help in making sure that this digital
process can work as quickly as possible with our CAF colleagues. And remember that this process
allows you to not only upload 2848 and 8821 with the electronic signature. It will also allow you
to upload those revocations as well. We want to make sure that those all flow as smoothly as
possible so that we can help you with your tax customer. Thank you. Anna Falkenstein: Okay. I
think I have one more for you here. It says, well, I think the question really meant to say, is
this format already available to submit online on the website, or when will it be available?
Andrew Chin: Yeah, thank you. So yes, the 2848 and 8821 are longstanding IRS forms, and they are
available on the IRS.gov website today. As Sharyn mentioned, we are making revisions. And those
revisions will be available prior to the availability of this platform for use in January of
2021. Anna Falkenstein: Okay. Sharyn, I think, I have one here for you. It says, do I understand
correctly, that simply typing a name on a PDF of the 2848 will qualify as an electronic
signature? Is there any further need to secure it? Sharyn Fisk: No. Well, you are correct of
that. No need to secure it. Yes, typing a name in a signature blocks is an electronic signature.
The security that we're looking for is done through this access through the Secure Access portal, where the person submitting it to the IRS is identifying themselves to their username and to
their passcode. So the IRS knows where this form is coming from. So that's where our security
lies on that particular document. Anna Falkenstein: Okay. You know what, Sharyn, just by you
saying that I'm just to take it a step further. So the person who has the Secure Access needs to
be the person who is submitting the 2848 or the 8821, not somebody in their staff? Is that
correct? Sharyn Fisk: Correct. Well, the person who is authenticating the taxpayer needs to be
the one who is submitting that form. Like, there's a question that basically, says, have you
authenticated this taxpayer? Or do you know the taxpayer from prior business relationship or
personal relationship? So we're just like you do under Circular 230. We want to see if you've
done your due diligence responsibilities and you know that, that form, you're submitting that
says, this is the taxpayer, this is their address, this is their Social Security number, and this
is their electronic signature is correct. Anna Falkenstein: Okay. Here's another question. I am
not very clear about the difference between electronic signatures and digital signatures, and
that's all it says? Sharyn Fisk: Yes. Yes. Yes. Those two terms get bandied about quite
frequently. So we think of it this way, an electronic signature, as I mentioned, could just be
typing a name in a signature block. There's no metadata attached to it, right. There's no secret
formula, such as you would use with some sort of a DocuSign. That's going to lock down your
computer IP address, and the date and the time you signed it. It's just typed. Or even if you
hand wrote your - someone hand wrote their signature, and then you scanned it, that scan is just
an image of a wet signature. There's no computer data attached to that signature. So those are
electronic signatures. And there's a whole broad category. One of the categories within
electronic signature is a digital signature. Now a digital signature is think of it is means of,
when the UPS person comes to your front door and you do that terrible signature with a finger as
a stylist, or you're at the grocery store and you use the stylist design, the little stylus pad
or the little signature block that is a digital signature, because it has all the data attached
to it. When did you sign it? How hard did you push that stylus? How quickly did that finger move
on that pad? So all of that data is stored to establish that digital signature, because as we all
know, and we use our fingers with stylus, it looks nothing like your legitimate signature,
right, your handwritten signature. Anna Falkenstein: Okay. Thank you very much. Andrew, I have
another one for you. Do we get an e-mail, if the Power of Attorney is rejected? Andrew Chin: No.
Anna Falkenstein: So they send something in, they don't? Andrew Chin: Yeah. Anna, if you want to
finish that question, feel free to do so. Anna Falkenstein: No. I was just - it was a very short
question. So I was just going to kind of step through, they send something in via the online
system. They do get a confirmation that it was received, when the CAF Unit is working at, if they
reject it, what's the next step? How are they notified? Sharyn Fisk: Can I pipe in on that one?
Anna Falkenstein: Sure. Sure. Sharyn Fisk: Yeah, I think we need to define about when the
rejection occurred. So this is just another means to get those authorizations into the CAF Unit.
So if it's rejected through the CAF Unit processing, right, the taxpayer, you drop the digit, or
you transpose the digit on the Social Security number, so it's not matching up on the IRS site,
you're going to get that regular rejection letter from the CAF Unit, saying, this Power of
Attorney is no good. If they're talking about the rejection, meaning, you've uploaded the
document. And for some reason, it doesn't go. That's an Andrew question. Andrew Chin: Yeah. To
that end, Sharyn, if you upload the document, and you don't see that success screen, that's your
first indication, right there. That it wasn't submitted to us. That it didn't fully make it over
to us. The second indication might be that the e-mail doesn't come over. So, again, once you've
seen that success screen at the very end, and they offer to either exit or restart the process to
upload another form. That's your cue right there that we did get it. And then, any issues with
form processing would be handled to Sharyn probably. Anna Falkenstein: Okay. I do have, there
seems to be a few very similar questions, so I'm going to - this is sort of a two-parter here.
Can you have both a wet signature and an e-signature on the same form? So maybe the taxpayer did
the wet signature, the Power of Attorney did the e-signature? This - I believe that, yes. But
the next part of that one of these other was can that be faxed? And I think, Sharyn, you
addressed that. But go ahead and address it again, since it's being asked. Sharyn Fisk: Sure. So,
yeah, you are correct. Yes, you can have it only applicable to the 2848 that's the only form that
has multiple signatures on it. But you could have a combination of the taxpayer, doing the
electronic signature, one of the practitioners doing a wet signature and another practitioner
doing electronic signature, so that the combination is input on that particular form. And those
forms do need to come through the online platform, because they are - they do contain an
electronic signature. And for the processing of the CAF Unit that just makes a very easy
delineation between processing the form. If it has an electronic signature, it must have come
through the online platform. If it has an electronic signature, it must come to the online
platform. If it has a wet signature, it can come through to fax, mail, eFax, or the online
platform. Anna Falkenstein: Excellent. Okay. I'll throw this out to either one of you can a
non-enrolled agent, I'm thinking this must be somebody who's not credentialed use the electronic
uploading options? Sharyn Fisk: Yes, they can, if they have a Secure Access account. So... Anna
Falkenstein: Okay. Sharyn Fisk: Yeah. Andrew Chin: Exactly. Anna Falkenstein: So they've got a
Secure Access account. They probably are wanting to put an 8821 in I'm assuming? Sharyn Fisk:
Correct. Probably to help with us, right. Get Transcripts for their clients or something like
that, yeah. Anna Falkenstein: Interesting. Here's a good one here, and we'll probably finishing
up here. But, for the summer 2021, you mentioned the new tax pro account, if they are to create
the 2848s or 8821s, does the client need their own online account to be able to sign and be
authenticated? Sharyn Fisk: Yeah, I got it. I'm picking up, like I'm putting down. Alright. Anna
Falkenstein: Okay, cool. Sharyn Fisk: So the tax pro account, you're going to need to match those
like your salt and pepper shaker going, you need the tax professionals who have their own tax pro
account, and you're going to need the client who have an individual taxpayer account. And that
is because when grabbing those digital signatures like the signatures that have all that metadata
attached to the computer that issued out that signature. So you will need those two pieces for
this online submission portal. You do not have to have your client have an individual taxpayer
account, because it is this is just a means to really put it in layman's terms, because I'm not
as technologically savvy as Andrew is. This is rather like an e-mail system. We're e-mailing our
authorization form to the IRS. Anna Falkenstein: Okay. Well, audience that's all the time we
have for questions. I think we did go a few minutes over, but I think they were important
questions to ask. So I do want to thank Sharyn and Andrew for sharing their knowledge and
expertise, and for answering these wonderful questions that you submitted. Before we close the
Q&A session, Sharyn and Andrew, can you give us a few key points that you want the attendees to
remember from today's webinar? Sharyn, why don't we start with you first? Sharyn Fisk: Sure. All
right. So just to remind you that if you haven't previously registered with the IRS for a Secure
Access account, let's say example, if you don't have e-Services to get your transcript, and so
you don't already have an IRS username and password, you'll need to register for Secure Access
and to do so soon, because it's a little bit of a registration, a two-step registration process,
you do have to wait for some feedback from the service. And you can go to IRS.gov/SecureAccess
has all that information, what you need to be successful. We've got virtual assist to help you
if you have problems with that registration. Again, if the client is unknown to you, and using an
electronic signature that they sign this form in a remote transaction, you have to authenticate
the taxpayer's identity. This is just your regular due diligence under Circular 230. And this is
not a perfect tool. We know that. It's a work in progress. And we will make adjustments as we
hear back. But this is something that we could put out now to help you and your clients navigate
through these difficult times. And brighter days are going to be ahead. We're going to launch
that all-digital process this coming summer, the tax pro accounts, and we'll keep you in the loop
on how that platform is going and going forward. Anna Falkenstein: All right, Andrew, how about
you? Do you have a couple of key points for us? Andrew Chin: I do. Thank you so much, Anna. So
I'll just build on top of what Sharyn noted. And while this might not be the perfect situation
and tool for each of you or your clients, we do encourage you to try this as much as possible. As
with all changes, it may be with some minor modifications that this will work great. And as
Sharyn mentioned, certainly it allows you to maintain a virtual presence and service your
clients entirely virtually. So that is certainly a plus. And we are delighted to be able to make
this available to you all. We continue to look for feedback. So please feel free to share that.
We do actually look at the surveys submitted on IRS.gov and other products. So please feel free
to send us feedback. And we do read it and we do take that to heart and continue to look to make
improvements. So thank you very much and we are excited to see these 2848s and 8821s come in.
Anna, back to you. Anna Falkenstein: Well, thank you - so, awesome. Thank you for those key
points. Audience, we are planning additional webinars throughout the year. To register for an
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