Less than two weeks after the IRS announced that it would temporarily permit the use of digital signatures by taxpayers and practitioners on 10 forms, the IRS expanded the list. The authorization is meant to reduce in-person contact during coronavirus pandemic. The IRS re-released the memorandum and added seven additional forms. Like the previously permitted forms, the new forms are the ones that are required to be paper filed. The newly added forms are:
- Form 706, U.S. Estate (and Generation-Skipping Transfer) Tax Return;
- Form 706-NA, U.S. Estate (and Generation-Skipping Transfer) Tax Return;
- Form 709, U.S. Gift (and Generation-Skipping Transfer) Tax Return;
- Form 1120- ND, Return for Nuclear Decommissioning Funds and Certain Related Persons;
- Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts; and
- Form 3520-A, Annual Information Return of Foreign Trust with a U.S. Owner.
The previously authorized forms were:
- Form 3115, Application for Change in Accounting Method;
- Form 8832, Entity Classification Election;
- Form 8802; Application for U.S. Residency Certification;
- Form 1066, U.S. Income Tax Return for Real Estate Mortgage Investment Conduit;
- Form 1120-RIC, U.S. Income Tax Return for Regulated Investment Companies;
- Form 1120-C, U.S. Income Tax Return for Cooperative Associations;
- Form 1120-REIT, U.S. Income Tax Return for Real Estate Investment Trusts;
- Form 1120-L, U.S. Life Insurance Company Income Tax Return;
- Form 1120-PC, U.S. Property and Casualty Insurance Company Income Tax Return; and
- Form 8453 series, Form 8878 series, and Form 8879 series regarding IRS e-file Signature Authorization Forms.
The temporary authorization for the use of digital signatures is effective for forms that are signed and postmarked beginning on or after Aug. 28, 2020, through Dec. 31, 2020. The updated memorandum retains the statement that the IRS will evaluate future use of digital signatures after the expiration of the memorandum’s authorization. That evaluation will consider the flexibility for taxpayers and tax practitioner while ensuring that the use of digital signatures does not create risks for tax administration.