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As highlighted in a prior September 10, 2020 LawFlash on this same topic, the IRS had announced on August 28, 2020 the temporary approval of the use of digital signatures in a news release ( IR-2020-194, the News Release). This News Release allowed a limited number of IRS forms to be digitally signed. The Memorandum is broader in scope and provides some clarity on what type of signatures are acceptable. In addition to digital signatures, the Memorandum specifically includes electronic signatures, and the IRS acknowledges that both electronic and digital signatures can appear in “many forms” and “may be created by many different technologies.” The Memorandum further states that the IRS is not requiring any specific technology for purposes of producing an electronic or digital signature during this temporary acceptance period. Thus, it appears the IRS is accepting images of signatures (scanned or photographed) and digital signatures (those using encryption techniques). Altho

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