Taxpayers with expiring ITINs should renew them now
The IRS has issued a Tax Tip reminding individuals with expiring Individual Tax Identification Numbers (ITINs) to renew their ITINs as soon as possible. Early renewal will help individuals avoid unnecessary delays related to tax refunds in 2020.
Background. Any individual filing a U.S. tax return is required to state his or her taxpayer identification number on that return. Generally, a taxpayer identification number is the individual’s Social Security number (SSN). However, the IRS issues ITINs to individuals who are not eligible to be issued an SSN but who still have a U.S. tax filing obligation. (Reg. §301.6109-1(d)(3)(i))
Unlike SSNs, ITINs expire if not used on a return for three consecutive years or after a certain period. For example, ITINs issued in 2011 and 2012 will expire on December 31, 2019. (Code Sec. 6109(i)(3)(B)(ii))
In June 2019, the IRS announced that it was beginning to accept ITIN renewal applications for ITINs expiring in December 2019. See IRS is accepting renewal applications for ITINs expiring by the end of 2019.
Reminder to renew ITIN. According to the IRS, ITINs with middle digits 83, 84, 85, 86 or 87, that have not already been renewed, will expire December 31, 2019, along with any ITINs that have not been used on a return in the last three years. These ITINs need to be renewed if the individual expects to have a filing requirement in 2020.
The IRS is sending out notices (CP48 Notice) to individuals whose ITINs are expiring. The CP48 Notice will provide instructions on how to renew an ITIN. Individuals who receive a CP 48 Notice from the IRS can renew any family ITINs together (a family is the filer, spouse and dependents), even if not all the family members’ ITINs are expiring.
To renew an ITIN, an individual must complete Form W-7 and submit all required documentation. Individuals do not need to attach a tax return to the Form W-7 but must note why they need an ITIN on that form.
There are three ways individuals can submit their renewal applications:
(1) mail the form to the IRS;
(2) work with a Certified Acceptance Agent authorized by the IRS to help individuals to obtain ITINs; or
(3) make an appointment at an IRS Taxpayer Assistance Center to have each applicant’s identity authenticated in person.
In this Tax Tip, the IRS also noted that ITINs with middle digits of 70 through 82, which have already expired, can be renewed at any time.
References: For the ITIN program, see FTC 2d/FIN ¶ S-1582.1 et seq.; United States Tax Reporter ¶ 61,094.