IRS Corporate Group Mailbox Has Upsides but Requires Forethought

The IRS’s new “corporate group mailbox” is a welcome step toward streamlining communications between large business taxpayers and the Independent Office of Appeals. But although these tools help make the appeals process more efficient, taxpayer representative teams should consider best practices for coordinating their responsive communications to the IRS.

Corporate group mailboxes will provide large business taxpayers that have multiple representatives a secure platform for communication and records sharing during the appeals process. The pilot program, which is available now through March 31, 2025, comes as part of the IRS’s broader initiative to modernize technology infrastructure with funding from the Inflation Reduction Act. It also responds to calls from the Treasury Inspector General For Tax Administration to increase the use and availability of digital communication tools.

Although secure messaging isn’t a new feature for taxpayers interacting with the IRS, it is one that, like other IRS technological modernization efforts, has unfolded slowly due to the agency’s obligations to ensure taxpayer privacy.

The IRS first piloted a secure messaging tool in December 2016 in the SB/SE Correspondence Examination function under the direction of the Taxpayer Digital Communication program. The program went on to implement other similar “installations” throughout the IRS, which, as of June 2021, included the Independent Office of Appeals Secure Messaging.

Until now, the IRS has generally conducted secure messaging through individual authorized representatives and shared files through the secure object repository mailbox. This structure puts the responsibility on a single representative to recommunicate messages and circulate files to the broader representative team. Absent precautions, this system could leave taxpayer representative teams vulnerable to overlooking key communications.

Group communication would keep key representatives up to date on communications to and from the Appeals office in real time. But the benefits of the corporate group mailbox also require caution.

While the IRS hasn’t announced practical details on the corporate group mailbox, it seems that all members of the taxpayer’s team of authorized representatives—including members of the taxpayer’s internal tax office—could directly contact and receive communications from Appeals. Without a plan in place, members of large representative teams could inadvertently undermine their appeals efforts with uncoordinated messaging.

Representative teams can avert these issues by planning ahead and adopting group procedures for communicating with Appeals. Taxpayer representatives who opt into the corporate group mailbox should internally coordinate responses to control the flow of information and ensure the team engages in strategic messaging that conveys a uniform position.

Any opportunity for representatives to streamline communications with the IRS without compromising privacy is a win for taxpayers and their representatives—especially for complex matters that require extensive back-and-forth between taxpayer representatives and Appeals.

It is unclear whether the corporate group mailbox will become permanent, but it is, at least conceptually, a step in the right direction.

This article does not necessarily reflect the opinion of Bloomberg Industry Group, Inc., the publisher of Bloomberg Law and Bloomberg Tax, or its owners.

Author Information

Stephen Josey is counsel at Vinson & Elkins’ tax controversy and litigation practice, where he represents taxpayers in disputes with the IRS at the administrative level and in court.

Margaret Hill is a tax associate at Vinson & Elkins and represents taxpayers in controversies involving complex domestic and international business transactions.

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