IRS Adds 6 More Forms to List That Temporarily Can Be Signed With Digital Signatures

The IRS has announced an additional six forms that will qualify for electronic signatures, in addition to the forms originally announced as eligible for this program on August 28.[1]

The new forms added to the list are:

  • Form 706, U.S. Estate (and Generation-Skipping Transfer) Tax Return;

  • Form 706-NA, U.S. Estate (and Generation-Skipping Transfer) Tax Return;

  • Form 709, U.S. Gift (and Generation-Skipping Transfer) Tax Return;

  • Form 1120-ND, Return for Nuclear Decommissioning Funds and Certain Related Persons;

  • Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts; and

  • Form 3520-A, Annual Information Return of Foreign Trust With a U.S. Owner.

These forms join the following forms originally on the list to qualify for electronic signatures:

  • Form 3115, Application for Change in Accounting Method;

  • Form 8832, Entity Classification Election;

  • Form 8802, Application for U.S. Residency Certification;

  • Form 1066, U.S. Income Tax Return for Real Estate Mortgage Investment Conduit;

  • Form 1120-RIC, U.S. Income Tax Return For Regulated Investment Companies;

  • Form 1120-C, U.S. Income Tax Return for Cooperative Associations;

  • Form 1120-REIT, U.S. Income Tax Return for Real Estate Investment Trusts;

  • Form 1120-L, U.S. Life Insurance Company Income Tax Return;

  • Form 1120-PC, U.S. Property and Casualty Insurance Company Income Tax Return; and

  • Form 8453 series, Form 8878 series, and Form 8879 series regarding IRS e-file Signature Authorization Forms.

These forms will be accepted with digital signatures so long as they are mailed on or before December 31, 2020.

The forms are ones that generally cannot be filed electronically and, thus, are normally mailed with the taxpayer’s pen and ink signature.

The memorandum, which retained its August 28, 2020 date but was simply revised to add the new forms, has the following information regarding the types of electronic signature technologies that can be used for this program:

Electronic and digital signatures appear in many forms when printed and may be created by many different technologies. No specific technology is required for this purpose during this temporary deviation.[2]


[1] “IRS adds six more forms to list that can be signed digitally; 16 now available,” IR 2020-206, September 10, 2020, https://www.irs.gov/newsroom/irs-adds-six-more-forms-to-list-that-can-be-signed-digitally-16-now-available (retrieved September 10, 2020); Memorandum from Susan B. Lough, Issued August 28, 2020, modified September 10, 2020, “Temporary Deviation from Handwritten Signature Requirement for Limited List of Tax Forms,” https://www.irs.gov/pub/irs-utl/updated-dcse-web-signature-memorandum.pdf (retrieved September 10, 2020)

[2] Memorandum from Susan B. Lough, Issued August 28, 2020, modified September 10, 2020, “Temporary Deviation from Handwritten Signature Requirement for Limited List of Tax Forms,” Footnote 1