The Internal Revenue Service recently updated its policy on electronic signatures in Internal Revenue Manual 10.10.1. That policy began during the COVID-19 pandemic and allowed for electronic signatures on certain IRS forms, including Form 706 (estate tax return), Form 706-GS (D), (generation-skipping transfer (GST) tax for distributions) and Form 706-GS (D-1), (notification of distribution from a GST trust). It was due to expire on Oct. 31, 2023, but the IRS extended it indefinitely “until more robust technical solutions are deployed,” according to IR-2023-199.
IR-2023-199 quotes Doug O’Donnell, Deputy Commissioner for Services and Enforcement, who notes that, “While these digital flexibilities were critical during the pandemic, it’s equally important to continue to offer options as the IRS moves toward a fully digital environment. We will continue to review our processes to identify areas where we can leverage technology to reduce burden on the tax community while maintaining critical security and protections against identity theft and fraud.”
The IRS also issued Interim Guidance Memorandum PGLD-10-1023-0002, which provides for the receipt and transmission of documents through Oct. 31, 2025, using email with encryption when working person-to-person with IRS personnel to address compliance or resolve issues in ongoing or follow-up authenticated interactions. IR-2023-199 says that the guidance will remain in effect until “the IRS fully implements long-term solutions for secure electronic communication channels with taxpayers as alternatives to encrypted email.”