Letter to the IRS on Forms 8822 and 8822–B

Dear Mr. Garcia:

The American Bankers Association (ABA) submits these comments in response to the request for comments on IRS Forms 8822 and 8822–B, recently issued by the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS).

Form 8822-B is generally used by businesses and other entities with Employer Identification Numbers to notify the IRS of mailing address changes, business location changes, and changes in responsible parties.

However, as detailed below, there are several issues related to the business address change process—including that there is currently no way for the IRS to determine if a Form 8822-B is authentic, in addition to the IRS accepting other methods of changing business addresses. These issues lead to major downstream problems for businesses, taxpayers, and the IRS.

ABA commends Treasury and the IRS for their ongoing efforts to improve address change processes and recommends several enhancements to strengthen the integrity and security of business address updates.

Namely, ABA recommends the IRS should institute additional controls related to business address changes, including notifying responsible parties via the IRS's Secure Object Repository (SOR) any time a business's address is changed.

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