The IRS issued IR-2020-181 on August 17, 2020 advising that more than 1 million Individual Taxpayer
Identification Numbers are set to expire at the end of 2020 as the Internal
Revenue Service completes the expiration of ITINs assigned prior to 2013. The
IRS continues to urge affected taxpayers to submit their renewal applications
early to avoid refund delays next year.
Under the Protecting Americans from Tax Hikes (PATH) Act, ITINs
that have not been used on a federal tax return at least once in the last three
consecutive years and those issued before 2013 will expire. This year ITINs
with middle digits 88 will expire Dec. 31, 2020. Additionally, ITINs with
middle digits 90, 91, 92, 94, 95, 96, 97, 98 or 99, that were assigned before
2013 and have not already been renewed, will also expire at the end of the
ITINs are used by people who have tax filing or payment
obligations under U.S. law but who are not eligible for a Social Security
number. ITIN holders who have questions should visit the ITIN information page on IRS.gov and
take a few minutes to understand the guidelines.
IRS continues a nationwide education effort to share information with ITIN
holders. To help taxpayers, the IRS offers a variety of informational materials, including flyers and
fact sheets, available in up to seven languages, including English, Spanish,
Chinese, Russian, Vietnamese, Korean and Haitian/Creole on IRS.gov.
Who should renew an ITIN
whose ITIN is expiring and who expect to have a filing requirement in 2021
must submit a renewal application. Others do not need to take any action.
ITINs with the middle digits 88 (For example: 9NN-88-NNNN) or 90, 91, 92,
94, 95, 96, 97, 98 or 99 (that meet the criteria above) need to be renewed
even if the taxpayer has used it in the last three years. The IRS will
begin sending the CP-48 Notice, You must renew your Individual Taxpayer Identification
Number (ITIN) to file your U.S. tax return, to affected taxpayers in
late summer. The notice explains that taxpayers will need to take action
to renew the ITIN if it will be included on a U.S. tax return filed in
2021. Taxpayers who receive the notice after acting to renew their ITIN do
not need to take further action unless another family member is affected.
a reminder, ITINs with middle digits 83 through 87 expired last year.
Middle digits 73 through 77, 81 and 82 expired in 2018. Middle digits 70,
71, 72, and 80 expired in 2017, and 78 and 79 expired in 2016. Taxpayers
with these ITIN numbers who expect to have a filing requirement in 2021
can renew at any time.
Family option remains available
Taxpayers with an expiring ITIN have the option to renew ITINs for
their entire family at the same time. Those who have received a renewal letter
from the IRS can choose to renew the family’s ITINs together, even if family
members have an ITIN with middle digits that have not been identified for
expiration. Family members include the tax filer, spouse and any dependents
claimed on the tax return.
How to renew an ITIN
To renew an ITIN, a taxpayer must complete a Form W-7 and submit all required
documentation. Taxpayers submitting a Form W-7 to renew their ITIN are not
required to attach a federal tax return. However, taxpayers must still note a
reason for needing an ITIN on the Form W-7. See the Form W-7 instructions for
Spouses and dependents residing outside of the U.S. only need to
renew their ITIN if filing an individual tax return, or if they qualify for an
allowable tax benefit (e.g., a dependent parent who qualifies the primary
taxpayer to claim head of household filing status.) In these instances, a
federal return must be attached to the Form W-7 renewal application.
There are three ways to submit the Form W-7 application package.
the form, along with original identification documents or copies certified
by the agency that issued them, to the IRS address listed on the Form W-7 instructions. The IRS will review the identification documents and
return them within 60 days.
Acceptance Agents (CAAs) authorized by the IRS to
help taxpayers apply for an ITIN. CAAs can authenticate all identification
documents for primary and secondary taxpayers, verify that an ITIN
application is correct before submitting it to the IRS for processing and
authenticate the passports and birth certificates for dependents. This
saves taxpayers from mailing original documents to the IRS.
advance, call and make an appointment at a designated IRS Taxpayer
to have each applicant’s identity authenticated in person instead of
mailing original identification documents to the IRS. Each family member
applying for an ITIN or renewal must be present at the appointment and
must have a completed Form W-7 and required identification documents. See
the TAC ITIN
page for more details.
Avoid common errors now and prevent delays next year
Federal tax returns that are submitted in 2021 with an expired
ITIN will be processed. However, certain tax credits and any exemptions will be
will receive a notice in the mail advising them of the change to their tax
return and their need to renew their ITIN. Once the ITIN is renewed, applicable
credits and exemptions will be restored, and any refunds will be issued.
several common errors can slow down some ITIN renewal applications. These
mistakes generally center on:
identification documentation without a Form W-7,
information on the Form W-7, or
supporting documentation, such as U.S. residency documentation or official
documentation to support name changes.
IRS urges any applicant to check over their form carefully before sending it to
the IRS. As a reminder, the IRS no longer accepts passports that do not have a
date of entry into the U.S. as a stand-alone identification document for
dependents other than U.S. military personnel overseas. The dependent’s
passport must have a date of entry stamp, otherwise the following additional
documents to prove U.S. residency are required:
medical records for dependents under age 6,
school records for dependents under age 18, and
school records (if a student), rental statements, bank statements or
utility bills listing the applicant’s name and U.S. address, if over age
To expand ITIN services, the IRS encourages individuals to apply
for the Acceptance Agent Program
To increase the availability of ITIN services nationwide,
particularly in communities with high ITIN usage, the IRS continues to actively
recruit Certifying Acceptance Agents and accepting applications
year-round. Interested individuals are encouraged to review all CAA program changes and requirements and submit an
application to become a CAA.
Have IRS Tax Problem?
Contact the Tax Lawyers at
Marini & Associates, P.A.