Efile QBI RREE without signature?

[igmcdowell]

I just finished my taxes and am preparing to file. I have a residential real estate enterprise that I claim QBI safe harbor on by filing a 199A Residential Real Estate Enterprise Statement.

In prior years TurboTax would not let me efile because the product had no support for the signature requirement. It now seems to be letting me efile, but I haven't signed this form in any way. I do notice the following language was added this year:

"By signing this return, we affirm the Rental Real Estate Enterprise described on this statement satisfies all requirements of the safe harbor set forth in Revenue Procedure 2019-38 for tax year 2021."

It seems like this is attempting to shift the signature requirement from form 199A to the full tax return signature.

However, below that there's a spot for a signature/date proceeded by the clause: "Under penalty of perjury, I (we) declare that I (we) have examined the statement..."

I'm concerned that if I efile without signing this form I'm going to get a letter from the IRS and have to submit my return by mail anyway.

Anyone have any insight on this? I swear I started the filing process a week ago and it refused to let me proceed with efile.  It'd be nice if I could get back on the efile train.

[igmcdowell]

I just read over Revenue Procedure 2019-38 and don't see anything about a signature requirement, so maybe TurboTax just generated a bad statement in the first place and we never needed it?

[PatriciaV]

You are correct that the Revenue Procedure requires that the taxpayer attached a statement that includes "a representation that the requirements of this revenue procedure have been satisfied," but doesn't specifically require that statement to be signed.

In general, your electronic signature for the e-filed return covers all included forms and documents.

However, you do have the option of printing the statement, signing, and scanning to a PDF that can be attached to your e-filed return.
You could also print, sign, and mail the statement after e-filing as a safety measure.

[whodiini]

"However, you do have the option of printing the statement, signing, and scanning to a PDF that can be attached to your e-filed return."

Can you elaborate exactly how to do that?  e.g. How do you attach a PDF to the return that can be efiled?    I am not exactly sure that is what you meant.  I would like to sign the statement, scan it and then attach it to the return that I can efile. I dont see a place in turbotax that asks for a pdf that I can place prior to efiling, 

Thank you

[DMarkM1]

You are correct.  If there were a requirement to attach a PDF to your return TurboTax would prompt you for that upload.  It is only in rare instances that a PDF is required.  Since there is no requirement for a separate signature page in this case there will not be a prompt. 

Your options are to e-file as is which meets the requirements in Revenue Procedure 2019-38 with your electronic signature on the return and be done or print/mail your return and also sign the statement page in that package. 

According to the instructions you are not not mail in any forms separately that are not on the form 8453.