The American Institute of CPAs asked the IRS to extend the use of electronic signatures for some forms by more than nine months, referencing COVID-19 obstacles.
Christopher W. Hesse, chair of the AICPA Tax Executive Committee, suggested in a December 10 letter that the IRS extend the expiration date of an August 28 memo — which temporarily permitted the use of electronic or digital signatures for some forms that required handwritten signatures — from December 31 through October 15, 2021.
The IRS issued a December 11 memo that expanded a temporary deviation for forms listed in the August 28 memo that are postmarked from January 1, 2021, through June 30, 2021, but didn't include all the forms requested by the AICPA. The memo also included several forms that weren’t originally in the August 28 memo, including Form 1128, “Application to Adopt, Change or Retain a Tax Year,” and the Form 8038 series that pertains to tax-exempt bonds.
The December 11 memo allows taxpayers and representatives to use electronic or digital signatures for forms including Form 3115, “Application for Change in Accounting Method”; Form 8832, “Entity Classification Election”; Form 8802, “Application for U.S. Residency Certification”; and Form 1066, “U.S. Income Tax Return for Real Estate Mortgage Investment Conduit.”
Other forms given temporary permissions in the latest memo include Forms 706 and 706-NA, “U.S. Estate (and Generation-Skipping Transfer) Tax Return,” and Form 709, “U.S. Gift (and Generation-Skipping Transfer) Tax Return.”
Hesse also urged the IRS to expand the scope of the August 28 memo to include non-income-tax returns and paper-filed returns. He also referenced a December 1 memo that temporarily allows IRS employees to accept images of signatures (scanned or photographed) and digital signatures on documents for the determination or collection of tax liability.
“Though the IRS acknowledges the burden of obtaining wet signatures on documents and has provided for its ability to continue the collection of tax liability through the December 1 memorandum, the scope is too narrow to truly benefit taxpayers and their representatives,” Hesse wrote.