Authorizing Someone to Deal With the CRA and the IRS for You: Form 2848, the CRA Representative Authorization, and What Each Actually Permits

The first practical problem in cross-border compliance is administrative: two agencies, two authorization regimes, and a taxpayer who wants one phone call to cover both. The IRS side. Form 2848, Power of Attorney and Declaration of Representative, authorizes a named individual to represent the taxpayer before the IRS — to receive and inspect confidential information, to sign certain documents, to negotiate, to respond to notices, and to represent in examinations and collection matters — for the specific tax matters (form type: income, employment, civil penalty), the specific years or periods, and the specific acts listed on the form; the representative must be eligible to practice before the IRS — an attorney, a certified public accountant licensed in a US state, an enrolled agent, or one of the narrower categories (an enrolled actuary, an unenrolled return preparer with limited representation rights for returns they prepared, a family member for certain matters) — and a Canadian accountant without US credentials cannot be named as a 2848 representative except in the limited unenrolled-preparer capacity for returns they prepared, which is why cross-border firms staff US-credentialed practitioners. Form 8821, Tax Information Authorization, is the lesser instrument: it authorizes the named person or firm to receive and inspect the taxpayer's confidential information for the listed matters and years — to obtain transcripts, to be copied on notices, to call the IRS about the account — without representation rights; anyone can be named (a firm, a Canadian accountant, a family member), and it is the form that lets a Canadian advisor monitor a client's IRS account and pull transcripts even where a US-credentialed colleague holds the 2848 for representation. Practicalities: both forms specify years (future years can be included up to three years beyond the current year), both are filed by fax or mail to the IRS's centralized unit or online through the practitioner's account (the online submission with the taxpayer's electronic signature is the modern route), both take weeks to process into the IRS's system (the CAF — centralized authorization file — number assigned to the representative is how the IRS tracks it), both can be revoked by the taxpayer in writing, and a 2848 with the "receive copies of notices" box checked is the instrument that lets the representative see the letter the taxpayer forgot to forward. The CRA side. The CRA's authorization runs through its online systems: the taxpayer authorizes a representative through My Account (entering the representative's RepID, GroupID, or business number), or the representative requests authorization through Represent a Client and the taxpayer confirms it in My Account — with the authorization taking effect quickly once confirmed; the paper route, Form AUT-01, authorizes offline access only (phone and mail, not online account access) and is the option for taxpayers without My Account; the taxpayer chooses a level of authorization — level 1 (view information only) or level 2 (view and make changes, request adjustments, submit documents) — and may set an expiry date or leave the authorization in effect until cancelled; and anyone with a RepID can be named — there is no credential requirement for CRA representation, so a US-credentialed practitioner without Canadian designations can be the CRA representative, and a Canadian accountant without US credentials can be the CRA representative alongside a US colleague's 2848. Non-resident taxpayers: a non-resident of Canada with a Canadian filing history (a section 216 or 217 filer, an emigrant with an open departure year) can authorize a representative the same way, and the non-resident's inability to register for My Account in some circumstances (no Canadian address, no recent Canadian return) routes them to the AUT-01 paper form, which is why the emigrant's CRA authorization is set up before departure while My Account access is easy. The cross-border setup: one firm with both a US-credentialed practitioner (the 2848 for representation; an 8821 to the firm for information) and a Canadian representative ID (the CRA authorization at level 2) — so that the client's notices from either agency reach someone who can answer them, transcripts and account information from both are accessible for planning and catch-up work, and the two authorizations are set up together at engagement rather than discovered missing during an audit; the years listed on the 2848 are extended each year (the form's future-year allowance is three years, so an annual refresh keeps it current), and the CRA authorization's expiry, if set, is calendared. What neither authorization is: a general power of attorney for financial or legal matters — a cross-border taxpayer's incapacity planning (a US durable power of attorney, a Canadian continuing power of attorney for property, and the question of whether each is recognized across the border) is a separate estate-planning document set that the two-wills guide's territory touches, and the tax authorizations expire with the taxpayer's death (the executor's own authorization, through the estate's identifiers in each system, replaces them). The one-form-per-agency reality means every cross-border client has at least two authorization documents on file, and the engagement letter that sets them up on day one is the reason the audit letter that arrives in year three gets answered on time.

Key takeaways

• IRS: Form 2848 for representation, Form 8821 for information. The 2848 names a credentialed practitioner (attorney, US CPA, enrolled agent, or limited categories) for listed matters and years; the 8821 names anyone — including a Canadian advisor — for access to transcripts and notices without representation.
• A Canadian accountant without US credentials cannot hold a 2848 except in the limited unenrolled-preparer capacity; the 8821 is their instrument for monitoring the client's IRS account.
• CRA: online authorization through My Account or Represent a Client (or Form AUT-01 for offline access), at level 1 (view) or level 2 (act), to anyone with a RepID — no credential requirement — until cancelled or the expiry set.
• Non-residents authorize the same way, with the AUT-01 paper route where My Account access is unavailable — set up before departure while access is easy.
• The cross-border setup is two authorizations at engagement: a 2848 (plus an 8821 to the firm) and a level-2 CRA authorization, refreshed annually for the 2848's future-year window, so notices from either agency reach someone who can answer.
• Neither is a general power of attorney: incapacity planning is a separate document set; tax authorizations end at death and the executor's own authorization replaces them.

The engagement-day authorization checklist

IRS: Form 2848 to the US-credentialed practitioner (matters: income tax and civil penalties; years: the open years plus three future years; notices box checked), submitted online with the client's electronic signature; Form 8821 to the firm for information access; CAF confirmation calendared. CRA: authorization at level 2 to the firm's RepID via My Account confirmation (or AUT-01 for a non-resident without account access); expiry set or left open. Annual: the 2848's years extended; the CRA expiry checked. Estate: the client's general powers of attorney noted in the file as a separate matter. Thirty minutes on day one; the alternative is a notice answered late because nobody could call.

Worked example

A Kelowna couple engages a cross-border firm for catch-up work in both countries. Day one: Form 2848 to the firm's enrolled agent for income tax matters and civil penalties covering the six catch-up years plus three future years, submitted online with both spouses' signatures; Form 8821 to the firm so the Canadian-side accountant can pull IRS transcripts for the streamlined scoping; CRA authorization at level 2 to the firm's RepID, confirmed by the couple in My Account the same afternoon. Month two: the transcripts pulled under the 8821 reveal a prior-year IRS notice the couple had never seen (mailed to an old address) — answered under the 2848 within the abatement window; the CRA account accessed at level 2 shows an unfiled T1135 demand — addressed in the VDP application. Month eight: the IRS's streamlined processing generates a matching notice; it arrives at the firm under the 2848's notices box the same week it arrives at the couple's home, and is answered before they've opened their copy. Year two: the 2848's years are extended; the CRA authorization has no expiry. The couple's neighbor, whose Canadian accountant "handles everything," discovered in an IRS examination that the accountant could not represent him (no US credential, no 2848), could not obtain his transcripts (no 8821), and had never seen the two prior notices that made the examination inevitable — an authorization problem that cost him a year and a US-credentialed representative hired mid-audit.

Official sources

The IRS explains: "Use Form 2848 to authorize an individual to represent you before the IRS," and that "the individual you authorize must be a person eligible to practice before the IRS"; Form 8821 instead authorizes a designee "to inspect and/or receive your confidential information" without representation. — Internal Revenue Service, About Form 2848, Power of Attorney and Declaration of Representative, https://www.irs.gov/forms-pubs/about-form-2848

The CRA explains that an individual may authorize a representative to deal with the CRA on their behalf — online through My Account or by the representative's request in Represent a Client, or by Form AUT-01 for offline access — choosing a level of authorization, and that the authorization remains in effect until cancelled or until the expiry date the taxpayer sets. — Canada Revenue Agency, Authorize a representative, https://www.canada.ca/en/revenue-agency/services/tax/representative-authorization.html

Practitioner note

Two agencies, two authorization regimes, and the cross-border client needs both set up on day one: the 2848 to a US-credentialed practitioner with the notices box checked, the 8821 so the Canadian side can pull transcripts, and the CRA's level-2 authorization confirmed in My Account before a departure makes access harder. Our engagement checklist does it in thirty minutes because the audit letter that arrives in year three is answered by whoever the authorizations reach — and the client who let their uncredentialed accountant 'handle everything' finds out mid-examination that nobody could.

See also: For how to put US income on a Canadian T1, see how to put US income on a Canadian T1; and browse every cross-border tax topic guide, organized by situation.

Next step

Fairlight prepares the authorization setup — Form 2848 and 8821 with matters, years, and notice routing, the CRA level-2 authorization via My Account or AUT-01 for non-residents, annual future-year extensions, and coordination with the client's separate incapacity and estate documents. See cross-border pricing or book a call.