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TAX PRACTICE & PROCEDURES

or letter, or a utility bill issued to the
business entity.
One major advantage Execution: One advantage of You also need
of having an submitting a Form 2848 or Form 8821 to know how to
online account is online is that the taxpayer does not upload the form
have to physically sign a printed piece
that you can of paper and scan or fax it back to the to the portal and, if
upload and submit practitioner. For this purpose, the IRS the situation arises,
allows an electronic signature. The IRS
a client’s third-party provides several acceptable methods for how to revoke
authorization forms affixing an electronic signature: a name or withdraw
(Form 2848 and that is typed on a signature block; a the form.
scanned or digitized image of a hand-
Form 8821) through written signature that is attached to an
the IRS’s ‘Submit electronic record; a handwritten signa- are married and file joint returns. This
ture input onto an electronic signature
Forms 2848 pad; a handwritten signature, mark, or annoyance started a few years ago when
and 8821 Online’ command input on a display screen with the IRS stopped allowing married tax-
portal. a stylus device; or a signature created by payers to complete a joint Form 2848
and started requiring that each spouse
third-party software. The ability to use
an electronic signature demonstrated its prepare and sign a separate form.
value during the pandemic with many Revoking or withdrawing the
taxpayers working from home without form: Generally, to revoke an authoriza-
moved since last filing a tax return and access to a printer and/or scanner, as tion that is already in place, the taxpayer
wants to use his or her updated address Forms 2848 or 8821 that are mailed or simply writes “REVOKE” across the
on the Form 2848 or Form 8821. In that faxed to the IRS must still be physically top of the Form 2848 or 8821 and
situation, you will still need to see the signed (i.e., a “wet signature”). signs and dates below it. Similarly, a
tax return to verify the individual’s SSN, Submitting the form: The first practitioner who wants to withdraw as a
but then you would use the utility bill to step to upload the form after logging in representative on a Form 2848 can write
verify the address that the person wants to the “Submit Forms 2848 and 8821 “WITHDRAW” across the top of the
to use on the form. This helps protect Online” portal is to start a session by first page of the form and sign and date
taxpayers from identity theft. inputting the taxpayer’s taxpayer iden- below it. Rather than having to mail or
For business-entity taxpayers signing tification number (TIN). This number fax in the withdrawal or revocation, such
a Form 2848 or Form 8821 remotely, is used to track the progress of the form can now be submitted through the
not only do you have to authenticate the authorization form. Then the completed “Submit Forms 2848 and 8821 Online”
identity of the person signing the return, form can be uploaded into the system portal by simply choosing “Revocation/
as explained above for individual taxpay- in either a PDF, JPEG, JPG, or GIF withdrawal of an existing authoriza-
ers, but you also need to make sure that file format. The IRS cautions not to tion” and following the instructions set
the individual has the proper author- upload any form that has already been out therein.
ity to sign the form on behalf of the submitted by fax or mail. The IRS says For more information about how to
business-entity taxpayer. Documentation that the Centralized Authorization File submit Forms 2848 and 8821 online, see
such as corporate minutes or an operat- unit processes all of the forms that it the FAQs posted on IRS.gov. ■
ing agreement could be used to satisfy receives, be it by online, mail, or fax, on a
this requirement. After verifying the first-in, first-out basis. Once the form is Contributor
signer’s identity, you would then need submitted, you will receive a confirma-
to record the name, employer iden- tion email. Ellen Brody, CPA, J.D., LL.M. (Tax), is a
tification number, and address of the As the forms are tracked by TIN, partner with Roberts & Holland LLP in
business-entity taxpayer. This infor- only one form can be submitted at a New York City. For more information on
mation must also be verified through time. You must start a new session each this column, contact
secondary information, including a tax time you file an additional form, even thetaxadviser@aicpa.org.
information reporting form, IRS notice if you are representing taxpayers who

42 October 2022 The Tax Adviser