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If you have an Individual Taxpayer Identification Number (ITIN), it may need to be renewed before the end of the year.

By Bethany Bouw

As we head into the tail-end of summer, it is good to take a moment to pause and consider if you need to renew your ITIN before the end of the year. The last thing anyone wants is to find out that their ITIN is expiring and there is no time left to renew. In accordance with the Protecting American’s from Tax Hikes Act of 2015 (the PATH Act), ITINs that have not been used on a federal return at least once in the last three years will expire on December 31, 2018. Additionally, ITINS bearing specific middle digits are also due to expire on the same date. The IRS is encouraging taxpayers to renew their ITINS as soon as possible to avoid delayed tax refunds and return processing.

Is my ITIN expiring on December 31, 2018?

ITINs that have middle digits of 73, 74, 75, 76, 77, 81 or 82 are set to expire on December 31, 2018. For example, if your ITIN is XXX-73-XXXX, you should consider renewing as soon as possible. You may also receive a notice (CP-48) of impending expiration if you have not used your ITIN on a federal return in at least one of the last three years. The notice includes an explanation of how to go about renewing the ITIN if needed for filing a return in 2019.

Do I need to renew my ITIN?

You do not need to renew your ITIN (or those of your spouse/dependents) if:

  • You have already renewed the ITIN prior to receiving the expiration notice (unless you have a family member with an expiring ITIN who requires renewal action).
  • You will not be using it on a 2018 US tax return to be filed in 2019.
  • A third party is only using the ITIN on informational return filings with the IRS.
  • The person who owns the ITIN now has a Social Security Number (SSN) (or is eligible to obtain an SSN). If so, you will need to respond to the tax notice providing your prior ITIN and new SSN.

How do I renew my ITIN?

Form W-7 must be submitted to the IRS in order to renew the ITIN. The form should be submitted with valid supporting original (or certified copies by the issuing agency) identification documents and any other required attachments. Renewal applicants must select the appropriate reason that the ITIN is required. If you receive a notice to renew your ITIN, make sure to include a copy of the notice with the Form W-7 application.

The IRS will be accepting renewal applications throughout the year.  It is highly recommended that renewals do not wait until the last minute. If the application is submitted before you are ready to file your return, you do not need to attach a tax return to the application.

Other ITIN information:

  • If your ITIN has middle digits of 78, 79, 70, 71, 72, and 80 that expired at the end of 2016 and 2017, you can renew them at any time.
  • The IRS is allowing family renewal. If you have a renewal letter for one member, you can renew the whole family’s ITINs together, even if the other members’ ITINs are not set to expire soon. A family member is considered a taxpayer, spouse, and dependents claimed on the return.

The International Tax Team at Ryan & Wetmore is well-versed in ITIN applications. For questions or concerns regarding your ITIN renewal, click here to email our foreign tax team.  Please be aware that tax issues are complicated and may vary based on the details of your situation. For this reason, an initial phone call is generally required to obtain the facts and address the questions.

Bethany Bouw CPA, is a manager at Ryan & Wetmore and has been with the firm for over eight years. She has experience with offshore voluntary compliance and assisting taxpayers with foreign asset and entity reporting requirements.

Traci Getz CPA, is a partner with Ryan & Wetmore, P.C. Traci has over fifteen years of experience providing accounting, tax, and consulting services to small and medium-sized business owners. She works with clients to understand their accounting and tax issues while specializing in international tax, healthcare, and construction.

Our firm provides the information in this e-newsletter for general guidance only, and does not constitute the provision of legal advice, tax advice, accounting services, investment advice, or professional consulting of any kind. The information provided herein should not be used as a substitute for consultation with professional tax, accounting, legal, or other competent advisers. Before making any decision or taking any action, you should consult a professional adviser who has been provided with all pertinent facts relevant to your particular situation. Tax articles in this e-newsletter are not intended to be used, and cannot be used by any taxpayer, for the purpose of avoiding accuracy-related penalties that may be imposed on the taxpayer. The information is provided “as is,” with no assurance or guarantee of completeness, accuracy, or timeliness of the information, and without warranty of any kind, express or implied, including but not limited to warranties of performance, merchantability, and fitness for a particular purpose.

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