rp-20-29.pdf

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Part III

Administrative, Procedural, and Miscellaneous

26 CFR 601.201: Rulings and determination letters

Rev. Proc. 2020-29

SECTION 1. PURPOSE
This revenue procedure modifies the procedures in Rev. Proc. 2020-1,
2020-1 I.R.B. 1 (Jan. 2, 2020), temporarily to allow for the electronic submission of
requests for letter rulings, closing agreements, determination letters, and information
letters under the jurisdiction of the Internal Revenue Service (IRS) Office of Chief
Counsel, and for determination letters issued by the IRS Large Business and
International Division (LB&I). Until this revenue procedure is modified or superseded,
both paper and electronic requests for advice described in section 2.01 of this revenue
procedure provided by Associate Chief Counsel Offices and LB&I, as defined in section
2.02 of this revenue procedure, will be accepted.
SECTION 2. BACKGROUND
.01 Revenue Procedure 2020-1 provides detailed information on how taxpayers can
request advice from the IRS in the form of letter rulings (including non-automatic
requests for changes in methods of accounting and non-automatic requests for changes

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in accounting periods), closing agreements, determination letters, and information letters
(together, requests for advice). Rev. Proc. 2020-1 generally requires taxpayers to submit
paper copies of written materials with wet signatures.
.02 For purposes of this revenue procedure, the term “Associate Chief Counsel
Offices and LB&I” collectively refers to the following Associate Chief Counsel offices and
LB&I: the Associate Chief Counsel (Corporate), the Associate Chief Counsel (Financial
Institutions and Products), the Associate Chief Counsel (Income Tax and Accounting),
the Associate Chief Counsel (International), the Associate Chief Counsel (Passthroughs
and Special Industries), the Associate Chief Counsel (Procedure and Administration),
and the Associate Chief Counsel (Employee Benefits, Exempt Organizations, and
Employment Taxes).
SECTION 3. OPTIONS FOR SUBMISSION OF REQUESTS FOR ADVICE
.01 Scope. This revenue procedure modifies Rev. Proc. 2020-1 to permit the
electronic submission of requests for advice from the Associate Chief Counsel Offices
and LB&I. This revenue procedure does not modify procedures for determination letters
issued by the IRS’s Small Business/Self Employed Division, Wage and Investment
Division, or Tax Exempt and Government Entities Division. Those procedures are
outlined in sections 7 and 12 of Rev. Proc. 2020-1, in Rev. Proc. 2020-4, 2020-1 I.R.B.
148 (Jan. 2, 2020), and in Rev. Proc. 2020-5, 2020-1 I.R.B. 241 (Jan. 2, 2020).
.02 Option for electronic submission. The IRS will accept electronic submissions for
requests for advice made for matters under the jurisdiction of Associate Chief Counsel
Offices and LB&I if the submissions are —

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(1) Transmitted by facsimile or compressed and encrypted email attachments using
the electronic submission procedures described in section 4 of this revenue procedure,
(2) Signed using the electronic signature procedures described in section 5 of this
revenue procedure.
.03 Option for paper submission. The IRS will also continue to accept requests for
advice as provided in Rev. Proc. 2020-1, although the IRS expects to have limited
personnel available, which will likely delay for some period of time the processing of
requests that are submitted in paper copies through the mail and private delivery
services. Electronic submission in accordance with this revenue procedure will allow for
more expeditious processing than paper submission.
SECTION 4. ELECTRONIC SUBMISSION PROCEDURES
.01 Submission by electronic facsimile . Taxpayers and their representatives are
encouraged to use a secure electronic facsimile service for transmitting requests for
advice. The secure electronic facsimile line for submitting requests under the jurisdiction
of any of the Associate Chief Counsel Offices is (877) 773-4950. The secure electronic
facsimile line for submitting determination letter requests under the jurisdiction of LB&I is
(844) 249-6231. To use the secure electronic facsimile method, first submit the full user
fee payment set forth in Appendix A of Rev. Proc. 2020-1 through
www.pay.gov. The
request package must include a copy of the receipt that is generated on the last page of
www.pay.gov with the completed form, a cover sheet, and the materials specified in Rev.
Proc. 2020-1, as modified by this revenue procedure. Provide clear titles for the
documents and distinguish files containing administrative forms and receipts from files
that contain the request itself and from supplemental materials. Transmit the full

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package, along with a cover sheet, to the IRS at the number indicated above for the
office with jurisdiction over the request. If the submission is over 10 MB or over 50
pages, break it into smaller components and number the components sequentially with
the total number, such as 1 of 4, 2 of 4, 3 of 4, and 4 of 4.
.02 Submission by compressed and encrypted email attachments. There are more
risks associated with compressed and encrypted email attachments than with electronic
facsimile, such as the possibility that sensitive taxpayer information could be intercepted.
Accordingly, the IRS encourages taxpayers and their representatives to use a secure
electronic facsimile service for transmitting requests for advice. As an alternative, this
section 4.02 provides procedures for using compressed and encrypted email
attachments for transmitting a request for advice under the jurisdiction of any of the
Associate Chief Counsel Offices and LB&I. The compression and encryption utility used
must be compatible with SecureZIP and allow the password-enabled encryption of email
attachments and other files. Both the sender and recipient must have the
decompression/ decryption utility installed. To compress and encrypt email attachments,
follow the directions provided by the program. Because these programs do not encrypt
the subject line, the body of the email, or the file name of the attachment, all taxpayer
information, including the name of the taxpayer, and return information should be
included only in the encrypted attachment.
(1) Compression utilities will request that the sender/ taxpayer create a password
for the recipient/ IRS to use to decrypt the attachments. The password should never be
sent in the same email with the encrypted attachment. Instead, it should be provided to

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the IRS in a separate email with a subject line that makes it easy to connect the
password to the encrypted email.
(2) The package for a request transmitted through email must include electronic
images of the Acknowledgement of Risks of Email (see Attachment A to this revenue
procedure) signed by the taxpayer or officer of the taxpayer (note this requires the
signature of the taxpayer, not the representative), the receipt that is generated on the
last page of www.pay.gov
, and all materials specified in Rev. Proc. 2020-1, as modified
by this revenue procedure. Provide clear titles for the documents and distinguish files
containing administrative forms and receipts from files containing the request itself and
from supplemental materials. Enable the compression and encryption utility on the email
system before generating the email. If a submission is over 5 MB, break it into smaller
components that do not exceed 5 MB each, and number the components sequentially
with the total number, such as 1 of 4, 2 of 4, 3 of 4, and 4 of 4. The email address for
requests that fall under the jurisdiction of any of the Associate Chief Counsel offices is:
Userfee@irscounsel.treas.gov. The email address for determination letter requests that
fall under the jurisdiction of LB&I is: lbi.irt.info@irs.gov.
.03 Submission of copies and originals. Taxpayers and their representatives do not
need to submit multiple copies of documents when submitting them electronically.
Where Rev. Proc. 2020-1 requires original forms or documents, submissions made
under the provisions of this revenue procedure will be sufficient.
.04 Submission of additional information and signed consent agreements. Any
additional information required for a ruling and signed consent agreements may be
submitted under the procedures set forth in this revenue procedure, but should be

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directed to the secure facsimile number or email address provided by the office
assigned to the request.
.05 Electronic submission after paper submission. Taxpayers who filed a paper
request and who have not received confirmation that it has been received and
processed may wish to make an electronic submission to ensure faster processing. If a
duplicate request is submitted electronically, please indicate on the request that it is a
duplicate submission of a paper submission
.
SECTION 5. ELECTRONIC SIGNATURE PROCEDURES
.01 This revenue procedure modifies Rev. Proc. 2020-01 to allow electronic
signatures to be submitted when wet signatures previously were required. This
modification applies to both paper and electronic submissions.
.02 The
IRS will accept the following images of signatures (scanned or
photographed) in one of the following formats: tiff, jpg, jpeg, pdf, Microsoft Office suite,
or Zip.
.03 The
IRS will accept digital signatures that use encryption techniques to provide
proof of original and unmodified documentation in one of the following formats: tiff, jpg,
jpeg, pdf, Microsoft Office suite, or Zip.
SECTION 6. CONFERENCES AND ISSUANCE OF ADVICE
.01 Conferences. Conferences will be conducted by telephone in the manner
provided in and subject to the requirements of Rev. Proc. 2020-1.
.02 Issuance of advice. The IRS has the discretion to determine the form in which it
will issue advice to the taxpayer, including transmittal by facsimile or email. The IRS
generally will follow established procedures for sending email if compressed and

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encrypted emails attachments will be used to correspond with the taxpayer.
SECTION 7. EFFECT ON OTHER DOCUMENTS
Rev. Proc. 2020-1 is modified.
SECTION 8. EFFECTIVE DATE
This revenue procedure is effective April 30, 2020, until modified or superseded.
SECTION 9. DRAFTING INFORMATION
The principal author of this revenue procedure is Teresa Dondlinger Trissell of the
Office of Associate Chief Counsel (Procedure & Administration). For further information
regarding this revenue proce dure, contact Ms. Trissell at (202) 317-3400 (not a toll- free
ca ll) .

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Attachment A

Acknowledgement of Risk with Email
I acknowledge that there are risks associated with email, such as the possibility
that sensitive taxpayer information could be intercepted and viewed by unauthorized
persons. I understand the importance of securing email using appropriate encryption,
particularly when transmitting sensitive or confidential tax-related information. I
understand that SecureZIP and compatible utilities only encrypt the email attachment
and not the subject line or the body of the email itself, and that confidential information
should not be included in the subject line, the body of the email itself, or the file name of
the attachment. By signing this agreement, I understand that sensitive or confidential
information should be sent only by compressed and encrypted email attachments in
communicating with the IRS.
Even with encryption it is possible electronic communications could be
intercepted. I acknowledge that the United States Government does not guarantee the
security of data transmitted electronically by email and accepts no liability, regardless of

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fault, for any loss or damage sustained without negligence of United States Government
employees.

(Name of Taxpayer)
(Title of Individual Signing Acknowledgment)

*SIGNATURE: _______________________________

DATE: _______________________________
*Signature must be from any person who could sign the return of the taxpayer, not a
representative. If the taxpayer is a corporation, the signature must be from an officer of
the corporation.