Expiring ITINS

Individual Taxpayer Identification Numbers (ITINs) are tax processing numbers, issued by the U.S. Internal Revenue Service (IRS), for certain resident and non-resident aliens, their spouses, and their dependents.  In general, no U.S. personal tax returns can be filed without a proper tax identification number (except when you are filing form W-7, “Application for IRS Individual Taxpayer Identification Number” with your initial U.S. personal tax filing).

An ITIN is used when a taxpayer does not qualify for a U.S. Social Security Number (SSN).   IRC §6109(i) provides the Secretary the authority to issue an individual taxpayer identification number.

On November 29, 2012 the IRS issued IR-2012-98, which indicated that ITINs, issued after January 1, 2013, would automatically expire after five years, even if used properly and regularly by taxpayers.  On June 30, 2014 the IRS issued IR-2014-76 changing the policy.  The revised policy was that ITINs would expire if the number had not been used in the last 5 years.  ITINs would stay in effect as long as a taxpayer continued to file U.S. tax returns.  The policy was then amended again, on August 16, 2016, such that ITINs will expire if not used in the last 3 years.

Each year a series of issued ITINs will expire.   Those taxpayers whose ITINs will expire should submit their renewal as soon as possible. Failure to renew them by the end of 2018 may cause refund and processing delays when their 2018 return is filed in 2019.

The following ITINs are now expiring and need to be renewed as soon as possible.

  • ITINs that expire at the end of 2018 have middle digits 73, 74, 75, 76, 77, 81 and 82 – for example: 9NN-73-NNNN.
  • Those who must renew their ITIN can choose to renew their family member’s ITINs together, even if family members have an ITIN with middle digits other than those listed above. Family members include the tax filer, spouse and any dependents claimed on the tax return.

Taxpayers who’s ITINs expired due to lack of use, should only renew their ITIN if they have a filing requirement for 2019.

To renew their ITIN, taxpayers must complete a new W-7 application and submit all required documentation.  Copies of documents must be certified by the issuing agency.  Those using a Canadian passport as proof, must have Passport Canada provide and certify the copy.  It has been our experience that if this is done, the W-7 application process is much smoother and more accurate.

Cadesky U.S. Tax Ltd. is a full service U.S. tax advisory and compliance firm.  If you need assistance with your W-7 application we would be glad to assist.  Please contact us for an appointment to discuss your situation.

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