Notable changes to Form 2848 include:
1. No electronic filing – The form can no longer be electronically filed.
2. PTIN Required – Un-enrolled preparers must include a valid PTIN.
3. Number of representatives - The number of representatives that a taxpayer can authorize on a single Form 2848 has been expanded from three to four. Attaching a supplemental list following the form instructions can designate additional representatives.
4. Limitation on copies - No more than two representatives may receive copies of notices and communications sent to the taxpayer by IRS.
5. Penalty representation must be specifically authorized. Historically, taxpayers who wished to authorize a representative to represent them with respect to penalties that are not related to a return had to specifically list “Civil Penalties” as a matter for which they were granting authority. The new form requires the specific penalty or payment to be listed. The following are the instructions for line 5b.
“Unless you specifically provide otherwise on line 5b, your authorization of tax matters on line 3 includes representation for penalties, payments, and interest related to a specific tax return. However, if the penalty or payment is not related to a return, you must enter “Civil Penalty,” “Section 4980H Shared Responsibility Payment,” or otherwise describe the specific penalty or payment for which you are authorizing representation in the “Description of Matter” column on line 3”
6. List of their powers of attorney. The Form 2848 instructions describes a method for representatives to receive a list of their powers of attorney recorded on IRS’s Central Authorization File (CAF).
7. Fax numbers. Form 2848 instructions provide a list of new fax numbers.