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Form 15094 belongs to one narrow situation. When the IRS Tax Exempt Bonds function opens an examination of a bond issue, the examiner often needs to share return information with a named third party such as bond counsel or a trustee, and this is the consent that authorizes it.
The signature date starts a clock. Under Treas. Reg. §301.6103(c)-1, the signed consent has to reach the IRS within 120 days. It authorizes disclosure only under IRC §6103(c); it does not appoint anyone to act for the taxpayer. For a non-TEB matter, Form 8821 covers disclosure and Form 2848 covers representation instead.
Key Takeaways
- IRS Form 15094, Consent to Disclose Tax Information (Rev. 6-2019), is the Tax Exempt Bonds (TEB) function's consent form, created under the office identifier SE:T:GESS:TEB. It authorizes the IRS to disclose return information to a named third party during a tax-exempt bond examination or compliance review.
- Form 15094 is a disclosure consent only, governed by IRC §6103(c) and Treas. Reg. §301.6103(c)-1. It does not appoint a representative and does not let the named party act on the taxpayer's behalf.
- Under Treas. Reg. §301.6103(c)-1, a signed Form 15094 must reach the IRS within 120 days of the taxpayer's signature date, and it must specifically identify the bond issue, tax periods, type of information, and named recipient. An open-ended consent does not satisfy the regulation.
- Form 15094 is not interchangeable with Form 8821. When a bond issuer wants the TEB examiner to discuss the matter directly with a conduit borrower, IRS guidance specifically requires Form 8821, Tax Information Authorization.
- For general, non-TEB disclosure use Form 8821; for representation before the IRS use Form 2848. These are separate authorities and do not replace the TEB-specific Form 15094.
Is Form 15094 the right form for your matter?
Form 15094 has one home: the Tax Exempt Bonds (TEB) function. Its embedded office identifier, SE:T:GESS:TEB, confirms it is a TEB-specific consent, not a general individual or business form. If the IRS has opened a bond examination or compliance review and the examiner asks you to authorize disclosure to bond counsel, a financial advisor, a trustee, or another named party, Form 15094, Consent to Disclose Tax Information (Rev. 6-2019), is the right document.
It is a disclosure consent only, governed by IRC §6103(c) and Treas. Reg. §301.6103(c)-1. Signing it lets the IRS share the return information you specify; it does not appoint a representative and it does not authorize the named party to negotiate or sign anything for you.
Quick check from my side of the desk: if this is a tax-exempt bond matter, use Form 15094. If it is an ordinary disclosure request with no bond examination behind it, Form 8821 is the general-purpose Tax Information Authorization. If you need someone to represent you before the IRS, that is Form 2848.
What Form 15094 authorizes, and what it does not
Form 15094 authorizes the IRS to disclose the return information you specify to the third party you name, in connection with a tax-exempt bond examination or compliance matter. It operates under IRC §6103(c), the subsection that lets the Secretary disclose a return or return information to the person the taxpayer designates in a written consent. Execution is voluntary: nobody is forced to sign, but without a consent the IRS cannot share otherwise confidential information with bond counsel, advisors, or other interested parties during the exam.
What Form 15094 allows
- The IRS may disclose the specifically identified bond-issue return information to the named recipient you designate.
- The consent must name the recipient and describe the tax periods and information categories being disclosed.
- It supports the TEB examination workflow, where the examiner may need to confirm facts with parties outside the issuer.
What Form 15094 does not allow
- No right to represent the taxpayer, argue a position, or sign agreements. That is Form 2848.
- No open-ended or blanket scope. Treas. Reg. §301.6103(c)-1 requires the consent to identify the specific return information disclosed.
- No waiver of the IRS's confidentiality obligations to other taxpayers. The consent covers only the signing taxpayer's own return information.
Form 15094 vs 8821 vs 2848, a quick side by side
| Item | Form 15094, TEB Consent to Disclose | Form 8821, Tax Information Authorization | Form 2848, Power of Attorney |
| Primary purpose | Consent to disclose return info in a TEB bond matter | Let IRS disclose your tax information generally | Allow representation before the IRS |
| Issued by / scope | TEB function (SE:T:GESS:TEB); bond examinations only | Any taxpayer, any non-TEB disclosure | Any taxpayer needing representation |
| Actions allowed | IRS may share named bond-issue information | Receive or inspect information | Speak for you, advocate, receive information |
| Governing authority | IRC §6103(c), Treas. Reg. §301.6103(c)-1 | IRC §6103(c) disclosure authority | Power-of-attorney authority, separate rules |
| 120-day receipt rule | Yes, §6103(c) consent | Yes, §6103(c) consent | No, not a §6103(c) consent |
Sources, IRS Form 15094 (Rev. 6-2019), TEB examination guidance, and Treas. Reg. §301.6103(c)-1.
How to submit Form 15094 in 2025
Form 15094 has no fixed annual deadline. It is submitted on demand as part of a TEB examination or compliance matter, and it routes back to the TEB office handling your bond issue. The controlling timing rule is the §6103(c) 120-day window: the IRS must receive the signed consent within 120 days of the date the taxpayer signed and dated it. Submit through the channel the TEB examiner specifies, and keep proof of transmission with your engagement file.
Practical submission notes
- The current revision is Rev. 6-2019; there is no annual "2025 version," so confirm on IRS.gov that no newer revision has been issued before you submit.
- Form 15094 is an Adobe LiveCycle XFA fillable PDF. Open it in Adobe Reader or Acrobat so the form fields render; a browser viewer may show only a "Please wait..." placeholder.
- Confirm with the assigned TEB examiner exactly which named recipient and which information should be on the consent before the taxpayer signs.
Tip, sign and submit so the IRS receives the consent well inside 120 days. After that window a fresh signature is required, even if the original was never revoked.
Step by step, complete Form 15094 accurately
The quickest way to avoid a rejected consent is to be exact about the bond issue, the information, the recipient, and the dates. Here is a simple path you can follow with the issuer or your team.
- Confirm the TEB matter Verify with the examiner that this is a tax-exempt bond examination or compliance review, and that Form 15094 is the consent they want on file rather than Form 8821.
- Identify the bond issue and information List the specific bond issue, tax periods, and the categories of return information to be disclosed. A valid §6103(c) consent must specifically identify the information; the IRS will not honor an open-ended scope.
- Name the recipient precisely Enter the named third party, for example bond counsel, a financial advisor, or a trustee, with complete contact details so the examiner can match the consent to the right party.
- Confirm voluntary execution Remember that signing is voluntary; the issuer is not legally required to consent, but without it the IRS cannot share confidential information during the exam.
- Sign, date, and submit inside 120 days Have the taxpayer sign and date the consent only after the scope is complete, then submit so the IRS receives it within 120 days. Keep proof of transmission with the engagement file.
Common mistakes that cause delays
- An open-ended or vague scope instead of a specific bond issue, tax period, and information category.
- Letting the 120-day window lapse between signature and IRS receipt, which forces a fresh consent.
- Reaching for Form 15094 when the examiner actually needs Form 8821 to talk directly with a conduit borrower.
- Assuming the blank "Please wait..." PDF is corrupt and abandoning the form instead of opening it in Adobe Reader.
Real‑world examples
- Bond counsel coordination, the TEB examiner needs to discuss return information for a specific municipal bond issue with the issuer's bond counsel. The issuer signs Form 15094 naming counsel, identifying the bond issue and the periods under exam, and submits it inside the 120-day window.
- Financial advisor on a compliance review, during a TEB compliance review the issuer wants its financial advisor to receive the relevant return information. A Form 15094 naming the advisor, scoped to that issue, lets the IRS disclose it without a power of attorney.
- Conduit borrower, here Form 15094 is not the right tool. When the examiner needs to speak directly with a conduit borrower, IRS guidance specifically requires Form 8821, Tax Information Authorization, instead. Confirm which the examiner wants before signing.
Security and privacy you should expect
Form 15094 opens a narrow, specific window into sensitive bond-issue information, nothing more. Under IRC §6103, returns and return information stay confidential except as authorized, so the consent only covers the signing taxpayer's own information and the specific items it identifies. It does not entitle the recipient to data about unrelated taxpayers, other bondholders, or other issuers. Scope each consent to a single matter, log the named recipient and the 120-day expiry, and refresh rather than stretch a stale signature.
Where Accountably fits for teams that care about control
On a TEB matter, the real risk is not a lack of forms, it is the handoff. The most common failure we see is a busy reviewer spending 40 minutes fixing an incomplete consent, chasing the right named recipient, or catching that the 120-day clock has nearly run out. A disciplined delivery system solves this: standardized templates for Form 15094, Form 8821, and Form 2848, a scope worksheet that pins down the bond issue and information categories before anyone signs, internal QA before submission, and a single tracked channel so transmittal evidence lands in the same place every time. That is the kind of operational plumbing Accountably builds into offshore delivery teams so senior reviewers stay focused on judgment work, not consent clean-up. Use it where it makes sense, skip it where it does not.
Bottom line, capacity without structure creates rework. A light process around these consents pays for itself in reduced chase time and fewer rejected submissions.
FAQ, continued
How long is a signed Form 15094 valid?
A signed Form 15094 must reach the IRS within 120 days of the date the taxpayer signed and dated it, per Treas. Reg. §301.6103(c)-1. After that window the consent is invalid even if it was never formally revoked, and a fresh signature is required.
Is there a 2025 version of Form 15094?
No. Form 15094 is not an annual return. The current revision is Rev. 6-2019 and it is used as-is across tax years until the IRS issues a new revision. Confirm on IRS.gov that no newer revision has been posted before you submit.
Does Form 15094 let the named party represent me?
No. Form 15094 is a disclosure consent only. It lets the IRS share return information; it does not appoint anyone to negotiate, sign, or speak on the taxpayer's behalf. For representation, file Form 2848, Power of Attorney and Declaration of Representative, in addition.
Why does my Form 15094 PDF open blank?
Form 15094 is an Adobe LiveCycle XFA-based PDF. Many browser viewers and non-Adobe readers show only a "Please wait..." placeholder. The file is not corrupt; download it and open it in Adobe Reader or Adobe Acrobat and the form fields will render.
Practical checklist for a Form 15094 consent
- Confirm this is a TEB bond matter, and that the examiner wants Form 15094 rather than Form 8821.
- Identify the specific bond issue, tax periods, and information categories, avoid vague or open-ended scope.
- Name the recipient precisely, and confirm contact details.
- Have the taxpayer sign and date only after the scope is complete.
- Submit so the IRS receives it within 120 days, keep proof with your engagement file, and log the expiry.
Key definitions at a glance
- Form 15094, Consent to Disclose Tax Information (Rev. 6-2019), the TEB function's consent that authorizes the IRS to disclose specified return information to a named third party during a tax-exempt bond examination. Disclosure only, governed by IRC §6103(c).
- Form 8821, Tax Information Authorization, the general-purpose disclosure authorization for non-TEB matters, and the form the IRS specifically requires for conduit-borrower communication in a bond exam.
- Form 2848, Power of Attorney and Declaration of Representative, allows an eligible representative to act for the taxpayer before the IRS for stated tax matters and periods.
Compliance note and freshness check
Form 15094 is not annual, but procedures around it can still shift. Always confirm on IRS.gov that Rev. 6-2019 is still current before you submit, and remember the 120-day receipt rule is the binding timing constraint. If you support TEB engagements, build a short SOP that includes a one-page scope worksheet, a naming standard for recipients, and a tracker that logs the signature date and 120-day expiry for every consent.
Closing
If you came here searching for "Form 15094," you most likely have a tax-exempt bond matter where the IRS needs to share return information with a named party. Now you know what the form does, that it is disclosure only under IRC §6103(c), that it must reach the IRS within 120 days of signature, and how it differs from Form 8821 (general disclosure, and the form required for conduit-borrower contact) and Form 2848 (representation). A little structure around these consents saves review time, prevents rejected submissions, and keeps the examination moving.
Common Mistakes We See Every Season
We see the same authorization mix-ups every season. The form is narrow but the search traffic around it is broad, and six patterns drive most of the rework.
Reusable Checklists
These are copy-paste ready for your firm SOP. The first runs before anyone signs, the second covers submission, and the third is a recurring authorization-hygiene scan.
Pre-sign scope worksheet
- Confirm whether the matter is a Tax Exempt Bonds (TEB) examination or a non-TEB disclosure request.
- If TEB and the examiner has asked for Form 15094, confirm the named recipient and the specific bond issue in writing.
- If non-TEB, default to Form 8821 for disclosure or Form 2848 for representation, not Form 15094.
- List the specific tax periods, tax types, and information categories to be disclosed.
- Confirm the designee's name, CAF number (if any), address, phone, and PTIN.
- Set the authorization end date or revocation trigger in writing.
- Have the taxpayer sign and date the consent only after the scope worksheet is complete.
120-day submission packet
- Stamp the signed consent with the date received from the taxpayer.
- Calculate the 120-day expiry from the signature date per Treas. Reg. §301.6103(c)-1 and add it to the tracker.
- Verify all signatures, dates, and scope fields are complete before transmission.
- Choose a single submission channel (Tax Pro Account, fax, or mail) and document the channel used.
- Save the transmittal confirmation in the client file.
- Calendar a 30-day check-in to confirm CAF processing and designee visibility.
Quarterly authorization-hygiene scan
- Pull a list of every active Form 8821, Form 2848, and TEB Form 15094 on file.
- Flag any consent older than 12 months for client confirmation or revocation.
- Revoke authorizations for departed staff designees within five business days.
- Match each active authorization against the underlying engagement; close the loop on anything orphaned.
- Re-issue consents that have expired or are approaching the 120-day window for newly active matters.
Keep 15094 Season From Stalling
Authorization work does not have a calendar peak the way Form 941 quarters or Form 1040 April do, but the volume is constant and the rejection cost is high. Per Treas. Reg. §301.6103(c)-1, every signed §6103(c) consent has a 120-day shelf life from the day the taxpayer signs it, and a single missed window forces a re-execution that backs up an entire client matter. Multiply that across a portfolio of hundreds of active authorizations and the cleanup hours compound fast.
The fix is not to add reviewers; it is to standardize the parts of the workflow that drift. A short SOP and a clean tracker turn authorization handling into a predictable, low-friction routine instead of a recurring source of escalations.
- Centralize a single tracker for Form 8821, Form 2848, and TEB-specific Form 15094, with signature date, scope, and channel logged at intake; track the 120-day expiry only for §6103(c) consents (Form 8821 and Form 15094), since Form 2848 is not subject to that rule.
- Build a one-page scope worksheet so each consent specifies bond issue or tax period, tax type, information category, and named recipient before anyone signs.
- Standardize the submission channel (Tax Pro Account, fax, or mail) per consent type so transmittal evidence lands in the same folder every time.
- Run a monthly review of consents older than 90 days; revoke or refresh before the 120-day window closes.
- Document the distinction between Form 15094 (TEB only), Form 8821 (general disclosure), and Form 2848 (representation) in the intake guide so new staff route requests correctly on day one.
This is the kind of structured execution we build into every engagement at Accountably. If you want the same authorization discipline running quietly in the background while senior reviewers focus on judgment work, our offshore tax delivery teams handle the SOP, the tracker, and the cycle without adding headcount.
FAQs
How long is a signed Form 15094 valid?
A signed Form 15094 must reach the IRS within 120 days of the date the taxpayer signed and dated it, per Treas. Reg. §301.6103(c)-1. After that window the consent is invalid even if it was never formally revoked, and a fresh signature is required.
Is there a 2025 version of Form 15094?
No. Form 15094 is not an annual return. The current revision is Rev. 6-2019 and it is used as-is across tax years until the IRS issues a new revision. Confirm on IRS.gov that no newer revision has been posted before you submit.
Does Form 15094 let the named party represent me?
No. Form 15094 is a disclosure consent only. It lets the IRS share return information; it does not appoint anyone to negotiate, sign, or speak on the taxpayer's behalf. For representation, file Form 2848, Power of Attorney and Declaration of Representative, in addition.
Why does my Form 15094 PDF open blank?
Form 15094 is an Adobe LiveCycle XFA-based PDF. Many browser viewers and non-Adobe readers show only a "Please wait..." placeholder. The file is not corrupt; download it and open it in Adobe Reader or Adobe Acrobat and the form fields will render.