Late last week, the IRS released Revenue Procedure 2020-29, which temporarily modifies the procedures in Rev. Proc. 2020-1 to allow for the electronic submission of certain requests for advice. Until otherwise noted, the IRS Office of Chief Counsel and the Large Business and International Division (“LB&I”) will now accept both paper and electronic submissions.
Rev. Proc. 2020-1
Rev. Proc. 2020-1, which is issued as the first revenue procedure every year, provides detailed information on how taxpayers can request advice from the IRS in the form of letter rulings (including non-automatic requests for changes in methods of accounting and non-automatic requests for changes in accounting periods), closing agreements, determination letters and information letters. Rev. Proc. 2020-1 generally requires taxpayers to submit paper copies of written materials with original signatures.
Rev. Proc. 2020-29
Rev. Proc. 2020-29 temporarily modifies the procedures in Rev. Proc. 2020-1 to provide that the IRS will accept electronic submissions for requests for advice made for matters under the jurisdiction of the Associate Chief Counsel Offices and LB&I. The electronic submissions will be accepted if they are (1) transmitted by fax or compressed and encrypted email attachments and (2) signed using electronic signature procedures. An “Acknowledgement of Risks of Email” statement must also be attached to the electronic transmission.
Rev. Pro. 2020-29 does not modify submission procedures for determination letters issued by the Small Business/Self-Employed, Wage and Investment, or Tax Exempt and Government Entities Divisions. Requests for advice from these divisions must continue to be mailed in.
The IRS expects to have limited personnel available, which will likely delay for some period of time the processing of requests that are submitted on paper. Electronic submission in accordance with this revenue procedure will allow for more expeditious processing than paper submission.
This is one more step the IRS has taken to allow for the electronic submission of documents and information which were previously required to be mailed in to allow for more expeditious processing. We will continue to monitor any changes to current procedures that provide additional methods for taxpayers to communicate with the IRS or expedite their claims. Please contact your Cherry Bekaert advisor with any questions.
