SECTION 4. ELECTRONIC

SUBMISSION PROCEDURES

.01 Submission by electronic facsim- ile . 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 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 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 informa- tion 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 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 re

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quest 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.