On November 29, 2012, the Internal Revenue Service (IRS) announced final revised application procedures and requirements for Individual Taxpayer Identification Numbers (ITINs). ITINs are issued to foreign individuals who are not eligible to obtain a social security number, but have filing and/or payment obligations under the Internal Revenue Code.
The revised application procedures (Revised Procedures) build on the interim procedures implemented earlier this year, with the goal of which is protecting the integrity of the ITIN application and refund process.
Previously, an ITIN application (Form W-7) simply required a notarized copy of an applicant’s passport to be attached to the application to confirm his or her identity. The interim procedures, now permanently implemented by the Revised Procedures, require ITIN applicants to supply original documentation, such as passports, birth certificates, or certified copies of such originals from the issuing agency. For example, if an applicant was issued their passport in the United Kingdom, to properly submit an ITIN application, such applicant would be required to either surrender their original passport to the IRS or obtain written certification of a copy of the passport from the issuing office in the United Kingdom. In addition, to help the IRS ensure ITINs are being used for legitimate tax purposes, the Revised Procedures provide that new ITINs will now expire after five years.
Following the implementation of the interim procedures earlier this year, IRS received comments from practitioners regarding the obvious difficulty that would arise for foreign individuals required to part with original documentation in their attempt to obtain an ITIN under the tightened procedure requirements. As a result, IRS is now providing alternative options to mailing in passports and other original documents to the ITIN centralized site when submitting an ITIN application.
In lieu surrendering original documentation with an ITIN application to the ITIN centralized site, applicants may file their applications and supply the requisite documentation to Certifying Acceptance Agents (CAAs), which are authorized to review original documents or copies certified by the document’s issuing agency, and certify the authenticity of such to IRS. In addition, applicants may visit certain IRS Taxpayer Assistance Centers (TACs), and the U.S. Tax Attachés in London, Paris, Beijing and Frankfurt, and CAAs located within the Low-Income Taxpayer Clinics and Volunteer Income Tax Assistance Centers which may assist with certain document certification and ITIN applications. However, with respect to dependent children, ITIN applications must still be submitted with original documentation whether completed through a CAA or applicant directly.
The Revised Procedures are effective January 1, 2013. Participating IRS TACs will be available to review and certify documentation in person for primary, secondary and dependent applicants later that month. The initial TACs will be available in areas where historical ITIN activity has been prevalent. Additional details regarding the TACs and participating IRS locations, and other rules will be made available in the near future on IRS’s website.
If you have questions or concerns about the ITIN application process or any IRS processes, please contact us at (941) 225-2615.
Koontz & Associates, PL
1613 Fruitville Rd
Sarasota, FL 34236
Phone: (941) 225-2615
Fax: (941) 951-2618