Key takeaways
- Form 8821 lets a third party receive tax information but does not let it speak for the client.
- Texas DPS accepts originals and certified copies only, so a photocopy of a driver license will not be accepted.
- A Texas driver license expired more than 2 years ago is not enough alone and needs a second document route.
- Confirm the Form 4506 fee on the current form before quoting it, because two IRS pages give different amounts.
Know which form asks for what
Form 4506, Request for Copy of Tax Return, asks the IRS for a copy of a return already filed, or designates a third party to receive it. The IRS page for the form lists the current revision as 0425. That page does not list identity documents for the signer, and I could not read the PDF to confirm the signature block.
Form 8821, Tax Information Authorization, lets a named third party inspect or receive tax information. The instructions say Form 8821 doesn't authorize your designee to speak on your behalf, and point to Form 2848 for representation before the IRS. The instructions I checked are revised 09/2021.
Decision rule: Decision rule: if the client needs the firm to talk to the IRS or represent the client before the IRS, the client needs Form 2848. If the client only needs transcripts delivered to the firm, read Form 8821 or Form 4506-T first. If the client needs copies of filed returns, read Form 4506.
Quote the Form 4506 fee carefully
IRS Tax Tip 2025-21, dated March 27, 2025, says there is a $30 fee for each copy of a return requested on Form 4506. A separate IRS privacy page says IRS charges a fee of $50.00 for each copy provided for a completed Form 4506. The two figures conflict, and the current form PDF was not readable when I checked it.
Do not quote a fee from memory. Check the fee printed on the revision the client is signing, and send the amount with the form.
Who signs Form 8821 for each entity type
For an individual, the taxpayer signs and dates Form 8821. On a joint return, the spouse must execute a separate Form 8821, so one signature does not cover both spouses.
For a corporation, the instructions say it is generally signed by an officer having authority under applicable state law to bind the corporation. For a partnership, a person who was a member of the partnership during the covered period generally can sign.
For a trust, a trustee having authority to bind the trust must sign with the title of trustee entered. If the current trustee has not been identified on a Form 56, one must be filed. For an estate, an executor having authority to bind the estate must sign, and the executor should be identified on a Form 56.
Decision rule: if the person signing for a trust is not named on the Form 56 on file, ask the client to file the Form 56 before the Form 8821 goes out. A Form 8821 signed by a bookkeeper who is not an officer or trustee does not meet the signer rule in the instructions.
Check the signer's ID for entities
For a business entity, the instructions say the third party must confirm through documentation that the individual signing has authority to sign on behalf of the taxpayer. They also say the third party must inspect a valid government-issued photo ID of the individual authorized to sign.
Ask for the officer's or trustee's photo ID, and match the title on the form to the Form 56 or state filing. Record the date and the staff member's name.
The 120-day window for lenders
When Form 8821 is used for a purpose other than resolving a tax matter with the IRS, such as income verification for a lender, the instructions say the IRS must receive the form within 120 days of the taxpayer's signature date. The 120-day limit does not apply to a form used to get help with a tax matter.
Example: a client signs a Form 8821 for a mortgage lender. The firm has 120 calendar days from that signature date to get the form to the IRS, so waiting for the client's other documents first can close the window.
Decision rule: when a lender sends a Form 8821, record the signature date and send the form to the IRS that week.
Texas DPS: the three routes
Texas DPS sets out three routes for identity documents when applying for a driver license or ID card. Route 1 takes one document that verifies identity alone. Route 2 takes two secondary documents. Route 3 takes one secondary document plus two supporting documents.
Route 1 documents include a Texas driver license or ID card not expired more than 2 years, a valid unexpired U.S. passport book or passport card, and an unexpired U.S. military ID card with an identifiable photo. Proof of citizenship may be required for a Texas driver license used this way.
Route 2 documents include an original or certified birth certificate issued by a State Bureau of Vital Statistics or equivalent agency, and an original or certified court order showing a legal name change. For U.S. citizens born abroad, the page lists a Consular Report of Birth Abroad issued by the U.S. Department of State.
Route 3 supporting documents include the Social Security card (actual card), Form W-2 or 1099, a driver license or ID card from another U.S. state that is unexpired or expired less than 2 years, a Texas driver license or ID card expired more than 2 years (actual card only), and a Texas voter registration card. Other supporting items include a Medicare or Medicaid card (actual card), Texas vehicle registration or title, and an insurance policy valid continuously for the past two years.
Route 3 items marked with an asterisk on the DPS page must be issued by a U.S. state, territory, D.C. or Canadian province institution, entity or government.
Originals, copies and name matches
The DPS page says documents must be original or certified copies. It says no photocopies can be accepted, and certified documents should not be laminated. Laminated copies of a birth certificate are not accepted.
The name and date of birth must match on all documents. If the name differs, the applicant must show a legal name change, using a marriage license, divorce decree, original or certified revised birth certificate, court-ordered name change, or a Department of State Health Services marriage verification letter.
Decision rule: if the name on the client's ID differs from the Social Security card or the W-2, ask for the marriage license or court order before the appointment. Do not wait for the counter to find the mismatch.
Documents clients send that get rejected
A photo of a Texas driver license sent to the firm for a DPS visit will not be accepted at the counter, because DPS does not accept photocopies. Fix it by bringing the original card, and keep the photo in the firm's file only as a reference.
A laminated birth certificate or a plain photocopy of one is not accepted under Route 2. Fix it by ordering a certified copy from the state vital records office, and tell the client not to laminate it.
A Texas driver license expired more than 2 years is not accepted alone. It counts only as the actual card under Route 3, so the client also needs a Route 2 secondary document and one more supporting document.
An out-of-state driver license expired more than 2 years is not on the Route 3 list. Fix it by asking for a supporting document from the lists above.
Bank statements, utility bills, leases and pay stubs are not on the DPS lists I checked. Ask for the Social Security card or a Form W-2 or 1099 instead.
A Form 8821 with no title on a trustee signature, or no officer signature on a corporation, goes back to the client. Fix it before the form is sent.
What to ask the client for, and the wording to use
For a DPS visit, send this wording: "Bring the original of one document from the list in this message to your DPS appointment. Photocopies and laminated copies are not accepted, so please leave them at home." Then check the Route the client is using before the appointment.
For an entity signature, send this wording: "Please have the officer who signs the form sign and date it in their own name, add their title, and send a photo of their government-issued photo ID with the form." Then check the title against the Form 56 on file.
Bank identity rules are set by each bank, and I did not check any bank's list. Use the bank's own written list before sending a client to the branch.