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Employee Plans News - June 8, 2012 - Form 2848: More Changes

A revised version of Form 2848, Power of Attorney and Declaration of Representative, was released in March 2012. Beginning March 1, the IRS’s three Centralized Authorization File processing sites:

  • stopped processing all powers of attorney that are not submitted on either the October 2011 or March 2012 versions of the Form 2848 unless a completed Form 2848 on one of these versions is attached. (Treas. Reg. section 601.503(b)(2)).
  • will continue processing powers of attorney submitted on either October 2011 or March 2012 versions of the Form 2848 until further guidance is issued.

Powers of attorney that will not be recorded on the CAF can be submitted on a document other than a Form 2848 as long as the document satisfies the requirements for a power of attorney. (Treas. Reg. section 601.503(a)).

Changes to Form 2848 affecting retirement plans:

Part I

 

Line 1 Taxpayer Information
  • The latest form has only one box for any type of taxpayer identification number.

  • Enter the 3-digit plan number in this area.

  • List only one taxpayer. The taxpayer is the plan sponsor on a Form 2848 submitted for a determination letter or VCP submission.

  • The plan and trust must submit separate Forms 2848 even if they are authorizing the same individual(s) to represent them.
 Line 2 Representative(s)
 
  • Check the box in the name and address area if you want your representative to receive notices and communications. This replaces Line 7 on the prior version of Form 2848. If no box is checked on Line 2 requesting copies of notices and communications be sent to the taxpayer’s authorized representative(s), the IRS will routinely send notices and communications only to the taxpayer. While IRS employees may continue to send copies of notices and communications to the taxpayer’s authorized representative in some situations, these courtesy copies will not be sent routinely unless a box is checked on Line 2.

  • Notice 2011-6 now generally requires a preparer tax identification number for most tax forms. Representatives who have applied for, but not received their PTIN may enter “applied for.”

  • Form 5500-series, VCP, and determination letter applications are exempt from the PTIN requirement. For retirement plans, the PTIN would only be required on Form 2848 in the event of a discrepancy adjustment.
 Line 3  Matters
  • The title “Tax Matters” has changed to “Matters” to reflect the use of the form for non-tax matters such as determination letters, closing agreements or the Employee Plans Compliance Resolution System (EPCRS).

  • Enter an explanation in the area titled “Description of Matter.” The plan number is also required in this area.

  • Enter the Tax Form Number and Year(s) or Period(s), if not applicable, enter “NA.”
 Line 4 Specific Use not recorded on CAF
  • An additional Employee Plans category was listed here: A Form 2848 covering an application for a determination letter is no longer recorded on the IRS’s Centralized Authorization File.
 Line 5  Acts Authorized
  • Check boxes have been provided to allow you to authorize your representative to perform certain actions not covered by the power of attorney without a specific authorization.

  • Ensure that all necessary boxes are checked.

  • For changes affecting unenrolled tax preparers, see "unenrolled tax preparers for Form 5500 examinations."
 Line 6 Retention/revocation of prior power(s) of attorney
  • This used to be Line 8.

  • Note that the old Line 6 used to refer to the receipt of refund checks. The CAF processing sites stopped processing taxpayer requests to have refund checks sent routinely to a named representative in November 2011.
 Line 7  Signature of Taxpayer
  • Latest form allows only one signature. Spouses (or former spouses) must now each file their own Form 2848.

  • As explained in the instructions, enter your PIN if you are submitting Form 2848 electronically.
Page Last Reviewed or Updated: 03-Apr-2014