The Reporting Agent List attached to Form 8655 is the client roster that tells the IRS exactly which taxpayers a reporting agent is authorized to act for. Each client needs a line on the list, and each line must carry the legal name, Employer Identification Number, and mailing address exactly as they appear in IRS records. Mismatches cause clients to drop out of the authorization, so the list is built by verification, not by copying what clients hand you.
What Each Entry on the List Must Contain
Three fields per client, and all three have to match the IRS master file:
- Legal name, as registered with the IRS. Trade names, DBAs, and abbreviations that don’t match will be rejected.
- The nine-digit EIN. This is the primary identifier the IRS uses to tie the agent’s actions to the taxpayer’s account.
- The complete business mailing address on file with the IRS.
If any of those fields disagrees with what the IRS has, that client won’t be covered by the authorization until you fix the entry and resubmit. You cannot file returns or make deposits for a client whose entry was dropped.
Verify EINs Before You Build the List
Most preventable rejections come from unverified EINs. Clients transpose digits, hand over numbers from prior entities, or confuse an EIN with a state tax ID. Copy those into your list and you’ll be reworking it later.
The cleanest source is the CP 575 notice the IRS issued when the EIN was first assigned. It shows the EIN and the legal name exactly as they sit in IRS systems. The IRS issues that notice only once, so clients who’ve lost it should request Letter 147C from the IRS business and specialty tax line to confirm a previously assigned EIN.1Internal Revenue Service. Employer Identification Number
For larger rosters, run the data through the IRS Taxpayer Identification Number Matching service before you assemble the list. It validates TIN-and-name pairs in interactive or bulk mode and requires enrollment with IRS e-Services on the Payer Account File database.2Internal Revenue Service. Taxpayer Identification Number (TIN) Matching Catching mismatches here saves weeks of correction later.
Format the List to Publication 1474
The list must follow the technical specifications in IRS Publication 1474, the technical guide for reporting agent authorizations and federal tax depositors.3Internal Revenue Service. Publication 1474 – Technical Specifications Guide For Reporting Agent Authorization and Federal Tax Depositors Keep the layout simple: separate columns for name, EIN, and address, no merged cells, no extra data fields. Cleaner files produce fewer processing errors.
Where to Send Form 8655 and the List
Every Form 8655 and its accompanying client list goes to a single address regardless of where the agent is located:
Internal Revenue Service
Accounts Management Service Center
MS 6748 RAF Team
1973 North Rulon White Blvd.
Ogden, UT 844044Internal Revenue Service. Form 8655 – Reporting Agent Authorization
Fax submission is available at 855-214-7523. Send no more than 25 forms per transmission, and the IRS recommends computer-based faxing rather than a physical fax machine where possible.4Internal Revenue Service. Form 8655 – Reporting Agent Authorization Publication 1474 also permits submission on compact disc.3Internal Revenue Service. Publication 1474 – Technical Specifications Guide For Reporting Agent Authorization and Federal Tax Depositors
Agents must submit Form 8655 before or at the same time as their IRS e-file application.5Internal Revenue Service. Reporting Agent Technical Fact Sheet Keep a complete copy of every submitted form and the full list. Save fax confirmations. If you mail, use a trackable method. Months later, when an account question comes up, you’ll want proof of what you sent and when.
Electronic Signatures
The IRS accepts electronic signatures on Form 8655, and the form instructions direct agents to Publication 1474, Section 01.03, for the approved authentication methods and the additional items that must appear on an electronically signed form.4Internal Revenue Service. Form 8655 – Reporting Agent Authorization Retain evidence of the authentication steps for each signed form. For agents onboarding many clients at once, e-signatures move the process along faster than collecting wet signatures on paper.
Processing and When the Authority Becomes Active
After submission, the data is entered into the Reporting Agents File, a database maintained at the Ogden campus that stores agent and client records.6Internal Revenue Service. Reporting Agents File (RAF) Do not assume the authority is active until the IRS confirms the request was accepted. Until then, the agent cannot sign, file, or make deposits for the pending clients.
Plan the timing accordingly. Submitting a batch of new Form 8655s in mid-March and expecting to file first-quarter 941s by April 30 is cutting it dangerously close.
Adding, Revoking, and Deleting Clients
Client rosters change. Businesses sign on, others leave, names change after restructurings. Each event calls for an update to the list.
To add clients, submit a new Form 8655 signed by each new client along with an updated list identifying the additions. Same formatting and verification standards apply. Mark the submission clearly as an update to an existing authorization rather than a fresh filing.
Revocation by the taxpayer works this way: the client sends a copy of the originally executed Form 8655 to the Ogden address, re-signs it under the original signature, and writes “REVOKE” across the top. If the client no longer has a copy, they can send a written statement identifying the reporting agent by name and address and stating the authority is revoked.4Internal Revenue Service. Form 8655 – Reporting Agent Authorization
If the agent wants to withdraw authority for a specific client, the agent files a signed written statement with the IRS identifying the taxpayer’s name and address and the authority being withdrawn. Publication 1474 also describes a delete process agents can use.4Internal Revenue Service. Form 8655 – Reporting Agent Authorization Either method goes to the same Ogden address or fax number as the original submission.
What the List Does Not Cover
Being on the Reporting Agent List is not the same as having a Power of Attorney. The authorization does not let the agent represent clients before the IRS, request penalty abatement, negotiate installment agreements, handle audits or appeals, sign consents extending the assessment period, or receive refund checks.7Internal Revenue Service. Reporting Agents File Tips and Tricks For that, a separate Form 2848 is needed, and only if the agent is otherwise qualified to practice before the IRS. Filing Form 8655 does not revoke an existing Form 2848 or Form 8821 the client may already have in place.4Internal Revenue Service. Form 8655 – Reporting Agent Authorization
The authorization also does not shift legal responsibility. The IRS holds the taxpayer accountable for timely filing and timely deposits even when a reporting agent handles them.4Internal Revenue Service. Form 8655 – Reporting Agent Authorization If the agent files late or deposits incorrectly, the penalty lands on the employer’s account. The employer may have a claim against the agent, but the IRS collects from the taxpayer.