The IRS has put into place mandatory renewal of Individual Taxpayer Identification Numbers (ITINs) for certain taxpayers beginning in 2017. An exception to this rule – taxpayers who only use an ITIN on an information return such as Form 1099 will not be required to renew their ITIN. Moreover, the filer of an informational return will not be penalized for those payees who use an expired ITIN.
Taxpayers filing a tax return will be required to renew their ITINs under the following timetables:
ITINs issued prior to 2013 will expire as follows (hint: the ITIN middle digit will be “78” or “79” on those issued prior to 2013):
- Issued before 2008 will expire January 1, 2017
- Issued in 2008 will expire January 1, 2018
- Issued in 2009-2010 will expire January 1,2019
- Issued in 2011-2012 will expire January 1, 2020
Any ITIN unused on a tax return for three consecutive years will need to be renewed.
Once the ITIN has been renewed, it remains valid until it is unused on a tax return for three consecutive years. Those taxpayers who have ITINs expiring January 1, 2017 may begin the renewal process as early as October 1, 2016. Using an expired ITIN on a tax return filing could cause delayed processing, delayed refunds and/or loss of tax credits such as the Child Tax Credit or American Opportunity Tax Credit.
The process for renewing an ITIN will be the same process used when applying for an original ITIN. The only difference is the IRS will not require a tax return to be attached to the W-7 form when renewing the ITIN. All other supporting documentation will be required as usual.
There is a new requirement in effect for dependents applying for ITINs. The IRS will no longer accept the passport as the sole supporting identification if there is no date of entry on the passport, unless the dependent is from Canada, Mexico or a dependent of overseas military. Those dependents will also need to submit medical data (under 6 years old), U.S. school records (under 18 years old) or a rental/bank/utility statement (dependent over 18 years old).
Please consult with a qualified tax professional should you have any questions or need any assistance with an ITIN renewal. If your ITIN is due to expire, be sure to begin the renewal processes as early as possible to ensure timely and smooth processing.
Jill A. Helm, CPA