May A Payroll Reporting Agent Sign And Submit Form 7200 On Behalf Of A Client Employer? – #63 ERC IRS Notice 2021-20

Question #63:
May a payroll reporting agent sign and submit Form 7200 on behalf of a client employer?

Found under the M. Special Issues for Employers: Use of Third-Party Payers section of the Employee Retention Credit (ERC) IRS Notice 2021-20 with updated guidance to help business owners follow the current ERC rules. 

The answer to question #63, May a payroll reporting agent sign and submit Form 7200 on behalf of a client employer?, can be found below.

ERC IRS Notice 2021-20 Question #63:

M. Special Issues for Employers: Use of Third-Party Payers

May a payroll reporting agent sign and submit Form 7200 on behalf of a client employer?

Yes. A payroll reporting agent may sign Form 7200 for a client employer for which it has the authority, via Form 8655, Reporting Agent Authorization, to sign and file the federal employment tax return. The signatory must be the Principal or Responsible Official listed on the Reporting Agent’s e-file application. The signatory may sign with ink on paper or may use the alternative signature method (rubber stamp, mechanical device, or computer software program; for details and required documentation, see Rev. Proc. 2005-39, 2005-28 I.R.B. 82). Consistent with Rev. Proc. 2005-39, an alternative signature must be in the form of a facsimile signature.

The reporting agent must obtain written authorization from the client employer (paper, fax, or e-mail) to perform these actions regarding the Form 7200. The reporting agent need not submit that authorization to the IRS, but should retain it in its files so that the reporting agent can furnish it to the IRS upon request. In the case of a client employer for which a third-party payer does not have a Reporting Agent

Authorization, the third-party payer may complete and print the form, or it may provide the client employer a means to complete and print the form, but the client employer will have to sign it.

The signatory for the reporting agent must sign, date, and print his or her name in the relevant boxes on Form 7200. In the box “Printed Title,” the signatory must include the reporting agent company name or name of business as it appeared on line 9 of the Form 8655. If the reporting agent company name or name of business from the Form 8655 is missing, the Form 7200 cannot be processed.

For more information about the Employee Retention Credit (ERC) IRS Notice 2021-20, visit the Internal Revenue Service (IRS) Department of the Treasury, official IRS.gov tax website.

Conclusion and Summary in May a payroll reporting agent signs and submits Form 7200 on behalf of a client employer? – #63 ERC IRS Notice 2021-20

The answer to Question #63: “May a payroll reporting agent sign and submit Form 7200 on behalf of a client employer?” was answered in detail above. It was found under section “M. Special Issues for Employers: Use of Third-Party Payers” in IRS Notice 2021-20. 

Leave a comment below if you have further questions on the Employee Retention Credit (ERC) or for clarifications in May a payroll reporting agent sign and submit Form 7200 on behalf of a client employer?

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Cover Image Credit: Irs.gov / IRS Notice 2021-20 / Disaster Loan Advisors.

Mark Monroe

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