Time is Running Out for Taxpayers to Renew ITINs by Marielys Rosado, CPA, JD, LLM
The deadline is approaching for certain non-U.S. persons with U.S. income tax-reporting obligations to renew the Individual Taxpayer Identification Numbers (ITINs) issued to them by the Internal Revenue Service (IRS). Failure to do so in a timely manner can result in significant delays in the processing of individuals’ federal tax returns and any related refunds they may be entitled to receive.
What is an ITIN?
The IRS issues nine-digit ITINs to individuals who do not have and are not eligible to receive Social Security Numbers required for the filing and processing of U.S. federal tax returns. This generally includes nonresident aliens and resident aliens required to file U.S. tax returns, dependents or spouses of U.S. citizens/resident aliens, and dependents or spouses of nonresident alien visa holders.
Who Needs to Renew an ITIN?
ITINs that expired on Dec. 31, 2021, include:
- those with the middle digits of 70, 71, 72, 73, 74, 75, 76, 77, 78, 79, 80, 81, 82, 83, 84, 85, 86, 87, or 88 (i.e. 9NN-88-NNNN);
- those with middle digits “90,” “91,” “92,” “94,” “95,” “96,” “97,” “98,” or “99,” if they were assigned before 2013; and
- and those that were not used on federal income tax return at least once during tax years 2018, 2019 or 2020.
Affected taxpayers should have received notification from the IRS advising them to renew their ITINs in order to file their 2021 U.S. tax returns.
if you do not have a U.S. tax return filing requirement for 2021, you may wait to renew your expired ITIN until the year that you do file or claim a refund.
How to Renew an Expired ITIN
The process for renewing an expired ITIN can be both complex and time intensive. Individuals must complete an updated IRS Form W-7 and gather original documentation (or certified copies) proving their identities and connections to a foreign country.
All documents must be submitted to the IRS along with the individual’s U.S. tax return by mail or via a certified acceptance agent (CAA), such as Berkowitz Pollack Brant Advisors + CPAs, who the IRS authorizes to facilitate the ITIN application and renewal process. The deadline for submitting this information is the individual’s 2021 tax return filing deadline, which is April 18 or June 15 for U.S. citizens or resident aliens residing overseas.
The IRS recommends that taxpayers with expired ITINs also use his time renew the ITINs for their spouses and children, even if those family members’ ITINs have not yet expired this year. Your spouse and dependents are not eligible to renew an ITIN unless you claim them as an allowable tax benefit, or they file their own tax returns.
The international tax advisors with Berkowitz Pollack Brant work with domestic and foreign individuals and multi-national businesses on a range of residency issues and financial matters, including pre-immigration planning, wealth preservation and tax efficiency across borders. The firm is also a Certified Acceptance Agent (CAAs) authorized by the IRS to help foreign individuals apply for and renew ITINs.
About the Author: Marielys Rosado, CPA, JD, LLM, is a senior manager of international tax services with Berkowitz Pollack Brent Advisors + Accountants where she provides tax compliance and consulting services to high-net-worth, multi-national families and business owners with operations in the U.S. and abroad. She can be reached at the CPA firm’s Miami office at (305) 379-7000 or info@bpbcpa.com.
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