If you are required to submit the information from your clients’ Forms 8655 electronically via the Secure Data Transfer (SDT) system along with the paper Forms 8655, all the data in the electronic files must match the data shown on the physical Forms 8655 (including the beginning periods/dates entered on lines 15 and 16). The most common errors made in completing Form 8655 are as follows: Missing taxpayer signature Missing taxpayer signature date. An unauthorized party signed the Form 8655. The individual signing Form 8655 must be authorized to bind the company. No beginning periods/dates indicated on lines 15, 16, or 18. Substitute Forms 8655 may be used to obtain and submit authorizations. You must follow the instructions in Publication 1167 to obtain approval prior to using forms other than the standard Form 8655. Although the authorization on Form 8655 is executable upon signature, it is required to be filed promptly with the Reporting Agent File (RAF) team. Faxing Form 8655 to an organization within the IRS, other than the RAF Team, does not satisfy the requirement to file the Reporting Agent Authorization (RAA) with the RAF Team following the processes described in Publication 1474. When entering a contract with a client for services, and on at least a quarterly basis thereafter, you must provide the client with a written statement that advises them that the authorization on Form 8655 does not relieve the client of the responsibility (or from liability for failing) to ensure that all tax returns are filed timely and that all Federal Tax Deposits (FTDs) and Federal Tax Payments (FTPs) are made timely. See Section 5.05 of Rev. Proc. 2012-32 for more information about this statement requirement including language guidelines. Generally, you are required to file tax returns on behalf of your clients electronically. See (2) in Section 4.02 of Rev. Proc. 2012-32 for exceptions when paper returns may be filed. You may generally only sign your clients’ returns if you file them electronically. The taxpayer (client) must sign all returns filed on paper unless one of the criteria listed in Section 5.06 of Rev. Proc. 2012-32 is met. The third-party authorization granted on Form 8655 may be used to obtain written information and/or verbally discuss information with regards to: Accounts/tax periods designated on lines 15 and 16 beginning with the period(s)/date(s) indicated. Applicable forms (and related civil penalties) if lines 18a (Forms W-2) and/or 18b (Forms1099) are completed. You may provide information to the IRS that can be considered in determining the outcome of an issue. However, the third-party authorization granted on Form 8655 does not allow you to represent your client before the IRS. The following are examples of activities that would be considered representation and would not be permitted by a Reporting Agent on behalf of their client: Requesting abatement or non-assertion of penalties. Opting out of filing Form 944. Formally representing clients before IRS Counsel, Appeals, Collection (including the Automated Collection System (ACS) and revenue officers (ROs), and Exam. Signing consents extending the time to assess tax. Recording interviews. Executing waivers agreeing to tax adjustments. Establishing an installment agreement. Receiving refund checks. Form 2848 may be used, by those who qualify, to obtain representational authorities. However, authorizations such as Form 2848 (or Form 8821) should only be obtained from the client if you need information regarding an account/tax period not covered by the Form 8655 or the client wishes you to act on their behalf in a manner which cannot be authorized via Form 8655. Successful enrollment in the Electronic Federal Tax Payment System (EFTPS) requires all entity items (EIN, name, and address) to exactly match IRS records. If you need confirmation/validation of entity items to enroll your client in EFTPS (or for other purposes): You may use e-services to view the complete entity information for your client if the Reporting Agent Authorization (RAA) granted on Form 8655 has been added to the Reporting Agent File (RAF). You may call Practitioner Priority Services (PPS) at (866) 860-4259 if the RAA has not been added to the RAF. You will then fax the physical Form 8655 to the assistor who will verbally confirm the entity information for valid authorizations. If two of the three entity items are correct, PPS is able to verbally provide one missing or incorrect entity item. If your client terminates service with you prior to the end of a filing period, do not file the applicable tax returns, including information returns (94X, W-2, etc.). This will prevent duplicate information being filed with the service which could cause compliance letters to be issued to your former client and their employees. The RAF Team will send you a monthly Revoke Listing which lists any client(s) that have started service with another RA, if applicable. Related topic Reporting Agents File (RAF)
