Taxation and Regulatory Compliance

What Is Form 8948 and Why Do Preparers File It?

Learn about the IRS e-file mandate for preparers and the function of Form 8948 in documenting a valid reason for submitting a paper tax return.

Form 8948, “Preparer Explanation for Not Filing Electronically,” is a document used by professional tax preparers. Its purpose is to accompany a paper-filed tax return that would otherwise be required to be submitted electronically. This form explains to the Internal Revenue Service (IRS) the specific reason why a preparer who is obligated to e-file has submitted a client’s return on paper.

The Preparer E-File Requirement

IRS regulations require any tax return preparer or firm that files 10 or more returns in a calendar year to use the IRS e-file system. This threshold is not limited to income tax returns but also includes other forms, such as information returns like Forms W-2 and 1099. If a preparer is subject to this requirement but files a paper return, Form 8948 must be attached to explain why.

Information Needed for Form 8948

A preparer must provide identifying information at the top of Form 8948. This includes the taxpayer’s name, identification number, and the tax year, along with the preparer’s name, address, and Preparer Tax Identification Number (PTIN). It is important to use the version of Form 8948 that corresponds to the correct tax year of the return being filed.

The form requires the preparer to select the specific reason for filing on paper from a list of IRS-approved exceptions. These include:

  • The client choosing to file on paper.
  • The tax preparation software not supporting a specific form or schedule.
  • An electronic return being rejected with an issue the preparer could not resolve.
  • The preparer having an approved undue hardship waiver from the IRS.
  • Being a member of a recognized religious group conscientiously opposed to e-filing.
  • Experiencing verifiable technology problems that prevented electronic submission.

For certain selections, such as a client’s choice, the preparer must maintain a separate signed statement from the client in their records but should not attach it to the tax return.

How to File Form 8948

Once completed, Form 8948 must be physically attached to the front of the client’s paper tax return. The entire package, consisting of the paper tax return with Form 8948 attached, is then mailed to the IRS.

The specific mailing address is not found on Form 8948 itself. Preparers must use the address provided in the instructions for the particular paper tax return being filed, such as the Form 1040 instructions. This ensures the return is sent to the correct IRS service center.

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