Should You Use 2848 or 8821?

Form 8821: Tax Information Authorization

Lets your firm view transcripts and receive copies of IRS notices.

Benefits

• Anyone at the firm can be named. No CPA, EA, or attorney credential required.

• Truss requires the designee’s CAF number to be linked to their Tax Pro Account to pull transcripts and create authorizations; the named individual designee must also have applied for and have access to the IRS Transcript Delivery System (TDS).

• View-only, so nothing you do under it binds the client.

• Quick and easy for clients to sign.

Watchouts

• You can call to get information, but you can’t advocate or resolve an issue.

• A new 8821 automatically revokes all prior 8821s unless you check the line 5 box and attach copies of the ones to keep. It does not revoke a 2848.

• The IRS must receive the form within 120 days of the client’s signature unless it is for help with a tax matter.

Form 2848: Power of Attorney

Everything an 8821 does, plus the right to represent the client before the IRS.

Benefits

• Call the IRS, respond to notices, request penalty abatement, set up payment plans, and attend exams.

• Faster resolution once a problem comes up.

Watchouts

• Only individuals eligible to practice before the IRS can be named, such as CPAs, EAs, and attorneys, plus a few limited categories tied to the client: its officers, its full-time employees, or family members. Form 2848 belongs to the person, not the firm.

• Your statements to the IRS bind the client, so liability is higher.

• You take on professional duties. As a representative, you’re subject to Circular 230. You must promptly provide records or information the IRS lawfully requests, tell the client about any noncompliance or error you find, and avoid unreasonable delay on the matter. Separately, if the firm receives a notice copy and nobody acts on it, the client may hold the firm responsible for a missed deadline. The IRS will still hold the client to it.

• Authorizing a representative does not shift responsibility. The IRS still sends original notices to the client and holds the client to every deadline.

• Unenrolled preparers need an active PTIN and a current Annual Filing Season Program record, and can only represent clients in exams of returns they prepared and signed.

• If the client signs first, the representative must sign within 45 days (60 if the client lives abroad), or the IRS won’t process the form. Having the representative sign first removes the deadline.

• Clients can be more hesitant to sign it due to the name and level of authorization.

Our recommended approach

File an 8821 for every client at onboarding or annual renewal so the firm can monitor transcripts and notices. File a 2848 only when a specific client, year, and issue needs representation.

Mailed copies of IRS notices

The IRS will mail your firm a copy of each notice it sends a client, but only if the client checks the applicable box under your name on the 8821 or 2848.

A few things to know

• Copies go to the address tied to your CAF number. Paper only. There is no email or portal delivery,
• You get the letter itself but not the response forms, publications, or payment vouchers that come with the client’s copy,
• Two per matter, across both forms. The IRS will send copies to at most two designees or representatives for the same tax matter, whether they are named on an 8821, a 2848, or a mix of both. Naming a third person is allowed, but the IRS will not mail them copies,
• The original goes to the client’s last known address, and that copy starts any deadline. A lost or late copy to the firm does not extend the client’s response time,

We recommend you pick one or two people at the firm to receive notices and keep them consistent across every authorization. If you use IRS Connect, you will usually see the alert notice post to the account before the mailed copy arrives.