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IRS : form 2678 Employer/Payer Appointment of Agent

For the past years the we have filed all of our payroll under one EIN even though we have two EINS. We have permission from the IRS to do this but we have received communication from the state Workforce in the recent months that we are now requiring the unemployment filings to be made under each EIN. We have filed the form 2678 Employer/Payer Appointment of Agent to revoke the agent’s appointment to file since 2017 but we have not received words from the IRS.

Basic question – can we build the new EIN and move the appropriate employees so that they are all being paid under the correct EIN without permission from the IRS or does that form need to be filed and approved before we break everything out? Thanks!


  • This is a Pat Haggerty type of question.

  • I am not clear, did you move all your employees into one EIN?
    When we filed under common the employees were assigned to separate EINs (the company in which they were hired). We did file one consolidate return (eg: 941 & 940). We were not allowed to file Unemployment under agent status. Things may have changed since then.
    Per IRS: "common pay agent" means an independent third party who contracts with, and represents, two or more employers, and who files a combined tax report for those employers. The operative words are "combined tax report for those employer". The third party is miss leading. An employer with multiple EINs would be considered the 3rd party who is applying for the agent status.

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