A small firm workflow for Form 2848 from signature through CAF posting

This page is general information, not legal advice. Form 2848, the Instructions for Form 2848, Circular 230, and the current IRS pages on Tax Pro Account and online submission are the texts to read. Have counsel review your authorization process before you treat this as the firm's process. This page does not invent representation rights, wait times, or penalties.

Use Form 2848 to authorize an individual to represent the taxpayer before the IRS. That individual must be eligible to practice before the IRS. Authorizing a qualifying representative also lets that person receive and inspect confidential tax information. Use Form 8821 if you want someone to inspect or receive confidential tax information and you do not want to authorize representation. (About Form 2848, Instructions for Form 2848)

The instructions are specific about what 2848 does not do by default. Representatives are not authorized to endorse or negotiate a government check for a federal tax liability. Unless you add it on line 5a, the form does not include substituting another representative, signing certain returns, or requesting disclosure to a third party. Unenrolled return preparers have limited representation rights and only for returns they prepared and signed, with extra Annual Filing Season Program rules for returns after 31 December 2015. Do not treat a signed 1040 engagement as a substitute for either form. (Instructions for Form 2848)

List the taxpayer, the representative, the description of the matter, the tax form number, and the years or periods. Do not write "All years," "All periods," or "All taxes." The IRS will return that power of attorney. You may list the current year, past years, and future years, but CAF will not record future years that go more than 3 years past 31 December of the year the IRS receives the form. Spouses who filed a joint return must each sign their own Form 2848. (Instructions for Form 2848)

If the representative already has a nine digit CAF number from a prior Form 2848 or Form 8821, enter it. If not, enter None and the IRS will issue one to the representative. CAF is not the SSN, EIN, PTIN, or enrollment card number, and it is not proof of authority to practice. The representative should use that CAF number on later powers of attorney. How the firm tracks CAF itself is the CAF number guide. (Instructions for Form 2848)

If you use an electronic signature, you must submit Form 2848 online. The IRS accepts a typed name in the signature block, a scanned handwritten signature, a signature pad, a stylus on a screen, or a third party software signature. Faxed and mailed forms need a wet ink signature. If you do not know the taxpayer and they sign electronically in a remote transaction, you must authenticate identity: government photo ID compared by photo or video, record name, SSN or ITIN, address, and date of birth, then verify with a second document. Keep that file. For a business, confirm the signer has authority. (Instructions for Form 2848, Submit Forms 2848 and 8821 online)

Tax Pro Account is the IRS path for individual power of attorney and tax information authorization without uploading a PDF, with processing the IRS describes as real time for those individual requests. You must have authority to practice as an attorney, CPA, enrolled agent, enrolled actuary, or enrolled retirement plan agent to request POA there. Anyone can request TIA. The taxpayer needs an address in a U.S. state or the District of Columbia that matches IRS records, and they approve the request in their IRS online account. Tax Pro Account currently covers listed individual matters (including Form 1040 income tax for calendar year filers from the last 20 years through the current year, plus 3 future years, with the limits on that page). Prior authorizations on file for the same tax matters, periods, and authorization types will be revoked unless you instead submit Form 2848 or Form 8821 and check the retention box. (Tax Pro Account)

If Tax Pro Account is not the right path (business taxpayers, a matter it does not list, or you already have a signed PDF), upload at the online submission page. Submit one form at a time, even for married filing jointly. PDF, JPG, or GIF, 15 MB. You get email that it was received. The IRS does not email you when it is processed. Check the Form 2848 and 8821 processing status page. If you already faxed or mailed it, do not also upload it. Electronic signatures go online, not by fax or mail. (Submit Forms 2848 and 8821 online)

If you need to discuss the case before the uploaded form is processed, the IRS says fax a wet ink form to the employee on the matter, or contact Practitioner Priority Service. Do not invent a processing time in days. Open the current status page before you tell a client a date.

CAF is the IRS computer file of authorization information. A specific use power of attorney (line 4) is not recorded on CAF the same way. For the ordinary recorded 2848, your tracker is not "we uploaded it." It is signature date, submission path, confirmation received, CAF posted (yes or no), and the years actually listed.

• View active authorizations in Tax Pro Account once the CAF number is linked.
• Check the Form 2848 and 8821 processing status page for uploaded, faxed, or mailed forms.
• Do not call on a matter until CAF shows the 2848, unless you are using the wet ink fax to the employee on that matter.
• Keep the signed PDF, the identity authentication file if it was remote, and the submission confirmation on the client.

Publication 4557 tells tax professionals to withdraw from outstanding authorizations for taxpayers who are no longer clients. Publication 5293 says the same if you have a CAF number: keep authorizations up to date and remove them for taxpayers who are no longer clients. Build withdraw into disengagement, not into a someday list. (Publication 4557, Publication 5293)

To withdraw as representative on a Form 2848, write WITHDRAW across the top of the first page, sign, and date below that note, then send it the way the instructions describe. Tax Pro Account also lets you withdraw an authorization, and the IRS says that withdrawal is removed from CAF immediately. To revoke, the taxpayer writes REVOKE across the top and signs. Use the current instructions. Do not skip the annotation. (Submit Forms 2848 and 8821 online, Instructions for Form 2848)

One row per client and form. Duplicate a row if they have both 2848 and 8821, or more than one year set.

Download the Form 2848 authorization tracker. The tax season operator can draft the chase when the signed 2848 is still missing. Your staff approve what goes out. Your CPA reviews and signs every return.