Reporting Agents File (RAF) Tips and Tricks

• If you are submitting the information from your clients’ Forms 8655 on magnetic media along with the paper Forms 8655, all the data on the magnetic media 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.
  • Unauthorized party has signed Form 8655. The individual signing must be authorized to bind the company.
  • No beginning periods/dates indicated on lines 15, 16, or 18.
• You may generally only sign your clients’ returns if you file them electronically. Otherwise, the taxpayer must sign all returns. EXCEPTION: If you meet one of the 5 criteria listed in Rev. Proc 2007-38, Section 5.06.
• 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 may cause compliance letters to be issued to your client and their employees. The RAF Team sends a monthly Revoke Listing which lists your client(s) whom have started service with another RA, if applicable.
• You must follow the instructions in Publication 1167 to obtain approval prior to using other than the standard Form 8655 (i.e. substitute 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 alleviate the need to file the Reporting Agent Authorization (RAA) with the RAF Team following the process described in Publication 1474.
• The third-party authorization granted on Form 8655 may be used to obtain written and/or verbally discuss information regarding accounts/modules indicated on lines 15 and 16 from the beginning period/date. If lines 18a (Forms W-2) and/or 18b (Forms1099) are completed, the authorization may be used to obtain written and/or verbally discuss information regarding the applicable form(s) and related civil penalties. Other authorizations such as Form 2848 or Form 8821 should only be acquired if you need information regarding an account/module not covered by the Form 8655.
• All entity items, EIN, name, and address, must match exactly for successful enrollment in the Electronic Federal Tax Payment System (EFTPS). If you require confirmation/validation of the entity items to enroll your client in EFTPS, or for other purposes, and:
  • If the Reporting Agent Authorization (RAA) granted on Form 8655 has been added to the Reporting Agent File (RAF), you may use e-services to view the complete entity information for your client.
  • If the RAA has not been added to the RAF, you may call Practitioner Priority Services (PPS) at (866) 860-4259. You will then fax the physical Form 8655 to the assistor who will verbally confirm the entity for valid authorizations. If two of the three entity items are correct, PPS is able to verbally provide one entity item if missing/incorrect.
• The third-party authorization granted on Form 8655 may not be used to represent your client. Following are some examples of activities that would be considered representation and would not be allowed by the RA under the Form 8655.
  • 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 installment agreement
  • Receiving refund checks
• You may, however, provide information to the IRS that can be considered in determining the outcome of an issue. Form 2848 may be used, by those who qualify, to obtain representational authorities.

References/Related Topics

• Reporting Agents File (RAF)