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people who had signed up for ID.me
               ID.me is also               prior to the implementation of this new   The IRS says that
                                           verification procedure, there is an option
             used by several               to allow them to have their previously   the Centralized
               other federal               submitted selfie deleted from the ID.me   Authorization File unit
                                           files if they so choose.
           agencies, including               Taxpayers and practitioners can elect   processes all of
           the Social Security             to verify their ID.me account under     the forms that

           Administration and              either method. Note that submitting the   it receives, be it
                                           photo identification and verifying with
            the Department of              a selfie generally takes a few minutes,    by online,
             Veterans Affairs,             while working with an ID.me agent        mail, or fax,
                                           requires the applicant to produce at least
                 and can be                two primary identification documents,    on a first-in,
             accessed using                and the wait time has been known to    first-out basis.
                                           often exceed an hour.
              the same login                 Once individuals are registered and
                information.               verified, not only can they access certain
                                           IRS information, but also 27 states use   portal, you must first authenticate the
                                           ID.me for their unemployment benefits   taxpayer’s identity if the individual is
                                           and other programs. ID.me is also used   electronically signing the form remotely
         their identity using their Social Secu-  by several other federal agencies, includ-  (meaning not in person) and you do not
         rity number (SSN) and some form of   ing the Social Security Administration   already have a personal or business rela-
         government-issued photo identification,   and the Department of Veterans Affairs,   tionship with him or her. A best practice
         specifically a driver’s license, a state-  and can be accessed using the same   is to routinely authenticate the taxpayer’s
         issued ID, or a passport. Then the per-  login information.         identity even if he or she is signing
         son would have to verify their identity by   It should be noted that the IRS has   in person. The objective behind this
         taking a selfie with either a smartphone   been exploring the viability of rolling   requirement is to ensure that the person
         or a computer with an enabled web-  out an alternative to ID.me that would   signing the form is, in fact, the person
         cam — and that selfie picture would be   operate through the General Services   they claim to be.
         matched to their previously provided   Administration-run website login.gov.  In order to authenticate the taxpayer’s
         photo identification.                                               identity, verification is done in a man-
           Numerous commentators, and several   Uploading Form 2848 and      ner similar to that used by the ID.me
         members of Congress, raised concerns   Form 8821                    registration platform. First, the taxpayer
         about the use of facial-recognition   One major advantage of having an on-  signing the form sends you for inspec-
         technology and the collection of such   line account is that you can upload and   tion a valid government-issued photo
         biometric identification by the IRS. In   submit a client’s third-party authoriza-  identification document. Then you have
         response, in February 2022, the IRS an-  tion forms (Form 2848 and Form 8821)   to compare the photo to the individual
         nounced the availability of an alternative   through the IRS’s “Submit Forms 2848   signing the form either via a selfie sent
         method to verify a user’s identity other   and 8821 Online” portal. In order to   to you by the taxpayer or by videoconfer-
         than the “selfie” method. While taxpay-  take advantage of this alternative to fax-  encing with the taxpayer. Next, there is a
         ers and practitioners still use ID.me to   ing or mailing in the form, you must: (1)   further verification of the person’s name,
         register for an online IRS account, they   authenticate that your client is who he   address, and SSN or individual taxpayer
         are now able to verify their identity via   or she claims to be and (2) have the per-  identification number through some
         an alternative method through a live   son properly execute the form. You also   form of secondary documentation. The
         online interview with an ID.me agent   need to know how to upload the form   recommended secondary information
         rather than submitting photo identifica-  to the portal and, if the situation arises,   includes a federal or state tax return or
         tion. While the live interview with the   how to revoke or withdraw the form.   IRS notice or letter and, possibly, also a
         ID.me agent is recorded, ID.me has   These matters are discussed below.  credit card statement or current utility
         stated that the video record is deleted   Authentication: To use the “Sub-  bill. The current credit card statement or
         after 30 days. Additionally, for those   mit Forms 2848 and 8821 Online”   utility bill is needed if the taxpayer has



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