IRS encourages early ITIN renewal to prevent refund delays as last round of ITINs are set to expire

The IRS released IR-2020-181 on August 17, 2020.  This issue notifies taxpayers of deadlines and considerations as they renew Individual Taxpayer Identification Numbers (“ITINs”).      

Since 1996, the IRS has issued ITINs to taxpayers and family members who are not eligible to receive a Social Security Number (SSN).  Prior to the 2015 Protecting Americans from Tax Hikes (PATH) Act, ITINs could be used indefinitely. ITINs assigned prior to 2013 are scheduled to expire. The PATH Act placed renewal requirement provisions into effect, starting in October 2016.  Since then, taxpayers using expired ITINs face refund delays and ineligibility for certain tax credits.  Renewals are being processed now.  ITINs that do not have a middle digit of 88, 90, 91, 92, 94, 95, 96, 97, 98 or 99 and not used on a tax return for tax years 2017, 2018 or 2019 will not expire in 2020.

Estimates total more than 1 million taxpayers hold potentially expiring ITINs. Expiring ITIN holders may have already received a letter from the IRS informing them of the December 31,2020 expiration date. Those not required to file a tax return are not required to renew the ITIN, however, if future reporting is expected, renewal consideration should be given.  

Three groups of taxpayers who need to renew follow:

  • ITINs that have not been used on a tax return for tax years 2017, 2018 or 2019 will expire December 31, 2020. 
  • ITINs with middle digits 88 (For example: 9NN-88-NNNN) will expire December 31, 2020. 
  • 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 this year. Even if the ITIN has been used in the last three years, if a filing requirement is expected in 2021, renewal is required. CP-48 Notice, informing taxpayers they need to renew their ITINs, will be sent in the coming months to inform taxpayers.  

What should you do if you need to renew your ITIN? To renew an ITIN, the taxpayer should complete Form W-7, “Application for IRS Individual Taxpayer Identification Number,” along with the required documentation. If you fall into one of the above categories, you do not need to wait to receive a CP-48 Notice to renew your ITIN. 

  • Three methods taxpayers can use to submit Form W-7 application package to renew their ITIN follow:
  1. IRS-authorized Certified Acceptance Agents or Acceptance Agents around the country 
  2. Form W-7 is to be completed and mailed, along with original identification documents or certified copies of the documents from the issuing Agency, to the IRS address listed on the form (identification documents will be returned within 60 days). A federal tax return is not required, however, a note explaining why an extension is being requested is required.   
  3. Schedule an appointment at an IRS Taxpayer Assistance Center to present documents to the IRS in-person rather than mailing documents.

The ITIN assignment date can be found on the CP565 ITIN Assignment notice.  If you no longer have your CP565, call the IRS at 1-800-829-1040 within the U.S., or 1-267-941-1000 (not a toll-free number) if you are outside the U.S.

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