PHILIP YAMALIS: So, ladies and gentlemen, it's the top of the hour, so let's go ahead and get
started. Welcome to today's webinar, Understanding Individual Taxpayer Identification Numbers,
or ITIN, as we call them. We are so happy you're joining us today. My name is Philip Yamalis and
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our session today. Let me take this opportunity to introduce our well-versed speakers today,
Joseph McCarthy and Richard Furlong. They're both tax specialists with the Internal Revenue
Service in the Communications and Liaison Division. They're my colleagues. They both work with
tax professionals and small business owners in their respective areas providing outreach and
education and identifying ways that the IRS could be more responsive to customers' needs. So,
let us begin. Let's turn it over to Rich to begin today's presentation. Welcome, Rich.
FURLONG: Well, thank you very much, Philip. And good day, everyone. Welcome to our webinar
today on the topic of Understanding Individual Taxpayer Identification Numbers, or as we will
refer to them during today's session, ITINs. My colleague, Joe McCarthy, and I will discuss the
who, the what, the where and the how of individual taxpayer identification numbers. Joe and I
will also be sharing information on ITINs, specifically how tax reform has made some changes to
whether or not one needs to obtain or renew an ITIN. And Joe and I will delve into the process
for the ITIN renewal applications. So, with that, let me turn it over to my colleague, Joe
McCarthy, to go over the objectives for today's session. JOSEPH MCCARTHY: Thank you, Rich. We
have a number of topics we're going to be discussing today and our objectives are, that by the
end of this presentation, you'll be able to describe the tax reform changes and the impact to
individual taxpayers identification number program, understand the W-7 application process for
ITIN renewals, understand common reasons for delays in processing W-7 applications, and identify
the law of certifying executive sessions. Rich, let me turn it back over to you to go over
today's agenda. FURLONG: Sure, Joe. So, let's look at the agenda for today's webinar. So, not
surprisingly, we'll begin with an overview of ITINs. Then, we'll follow up with a discussion of
how tax reform has impacted the ITIN process. Joe and I will discuss who should and, most
importantly, who should not renew their ITIN. And then, we'll look at the process of renewing
an ITIN and when to renew. And then, finally, we will review common reasons for delay in the
processing of a Form W-7, then, we'll wrap it up with a discussion of certifying acceptance
agents and the important role they, they share with us in the ITIN process, excuse me. So, let me
begin with some background information on the ITIN program. So, what is an ITIN? An Individual
Taxpayer Identification Number is simply a nine-digit number. It always starts with the number
"9". It is a tax processing number issued by the Internal Revenue Service to specific groups of
people and those would be individuals who are required to have a U.S. taxpayer identification
number, but there are individuals who do not have, and they are not eligible to obtain a social
security number. And finally, they have a U.S. filing or reporting requirement. Now, the IRS
issues ITINs to help these individuals comply with United States tax laws and also to provide us
here at, IRS, a means to efficiently process and account for the tax returns being submitted and
the payments coming in with those returns. ITINs are issued regardless of one's immigration
status. And that is because both resident and non-resident aliens under U.S. tax law may have a
U.S. filing or reporting requirement. It's important to remember that ITINs do not serve any
purpose other than for federal tax reporting and they are not intended to use outside the
federal tax system. MCCARTHY: Richard, let me get this straight. ITINs are used only for tax
purposes, right? FURLONG: Joe, thanks for asking that question. And it's very important for
everyone to understand that that is correct. ITINs are only for U.S. federal tax purposes and
they are issued, again, to individuals who have a U.S. filing or reporting requirement and those
individuals are not eligible to obtain a social security number from the Social Security
Administration. Again, it bears repeating that ITINs help individuals comply with U.S. tax laws.
They also encourage voluntary tax compliance for those individuals, and they provide a means for
us here at the IRS to process those tax returns once filed and for those individuals to make tax
payments. MCCARTHY: Just a quick follow up, ITINs do not make you eligible to work in the United
States, do they? FURLONG: Joe, that's another common question you and I have heard and you're
correct. And ITIN in and of itself does not make one eligible to work in the U.S. I want to
repeat that because it is important. ITINs do not make one eligible to work in the United
States and, that said, ITINs are issued to individuals regardless of that individual's
immigration status. So, Phil, let's pause for a moment and I think we are ready to tee up our
first polling question. YAMALIS: We certainly are, Rich. That sounds like a great idea.
Audience, as a reminder, please ensure that you have disabled your pop-up blockers so that you
can answer the questions. So, here's our first polling question. Which of these is not a true
statement regarding ITINs? Is it a) all ITINs begin with the number "9", b) ITINs are only
issued to individuals who are not eligible for social security numbers, c) ITINs assist in the
efficient processing of tax returns and payments, d) an ITIN may be used to obtain a United
States driver's license? Which of these is not a true statement regarding ITINs? Please take a
minute, review the question again, and then, click in the radio button which you believe most
closely answers this question. We'll give everyone a few more seconds to make your selection.
OK. Let's stop the polling now and we'll share the correct answer on the next slide. There it
is. The correct response, as you can see, is D, an ITIN may not be used to obtain a United
States driver's license. I see that 87 percent of you responded correctly. That's a pretty good
response rate. Thank you all of you that are paying attention. Why don't we turn it over to
you, Joe? Did you want to talk to us about how the Tax Cuts and Jobs Act affects ITINs?
MCCARTHY: Absolutely, Phil. The Tax Cuts and Jobs Act in 2017 resulted in significant changes
to the Individual Taxpayer Identification Number rules for some taxpayers. One of the most
important changes of the act is that it suspended the deduction for personal exemptions for tax
years 2018 to 2025. As a result, most spouses and dependents residing outside of the United
States don't need to apply for or renew their ITINs this year because there are no tax benefits
for having an ITIN. Again, this is only for most spouses and dependents residing outside of the
United States. We'll discuss some of the exceptions to this rule later in the presentation.
Spouses and dependents residing in the United States will still have to apply for or renew
their ITINs when appropriate. Rich, can you talk about who should renew their ITINs? FURLONG:
Certainly, Joe. So, it's important for everyone attending today to understand who should renew
the ITIN for 2020. So, the first situation will be if they expect to file a U.S. federal tax
return in 2020 or if their ITIN has not been used on at least one federal tax return in the last
three consecutive tax years or if their ITIN was issued before 2013. Now, the expiring of ITINs
issued before 2013, that process began several years ago in December of 2016 and it ended on
December 31, 2019. Again, those that was for ITINs issued prior to 2013. And that's why the
bullet on the screen states that ITINs with the middle two digits that fall in the range of 70 to
87, those ITINs have all expired. And these changes were as a result of federal tax legislation
passed in late 2015, that was entitled Protecting Americans from Tax Hikes Act or the PATH Act.
MCCARTHY: So, let me get this straight, Rich, taxpayers who are expected to file a U.S. tax
federal tax return in 2020 and who have not used their ITIN in at least one tax return in the
last three consecutive tax years or if their ITIN is issued before 2013, they have to renew
their ITIN? FURLONG: Joe, that's correct. You nailed it. Those any one of those three
categories, they would have to renew their ITIN. MCCARTHY: OK, Rich, I'll go over the last few
points here. Taxpayers should renew their ITINs if they have received a notice CP-40A from the
Internal Revenue Service titled "You Must Renew Your Individual Taxpayer Identification Number";
or have spouses and dependents that are residing inside the United States, it will be included
on the tax return in 2020. Now, let's review when taxpayers do not have to review renew their
ITINs. So, taxpayers do not have to renew their ITINs in 2020 if the taxpayer does not expect to
file a tax return in 2020; separately, if a taxpayer's spouse or dependents would not be
included on a U.S. federal tax return in 2020, the spouse or dependents would not have to renew
their ITINs. Taxpayers whose ITINs are used only on third-party information returns such as Form
1099 don't have to be renewed. That said, expired ITINs can still be used for informational
return purposes only. If the taxpayer subsequently has a need to submit a tax return, they can
renew their ITIN at that time. And finally, taxpayers who have become U.S. citizens or legal
resident aliens and are issued social security numbers do not have to renew their ITINs in 2020.
FURLONG: Joe, let me jump in here with a question that I've heard before and I think you
probably have also. What exactly happens when an ITIN holder subsequently receives a social
security number because they become eligible for a social security number? MCCARTHY: Well,
you're right, Rich, I have heard that question numerous times before. So, if an ITIN holder
subsequently receives a social security number, they should notify the IRS. That way, the IRS
can merge the person's social security number and their Individual Taxpayer Identification Number
into one account. The ITIN holder can notify the IRS that they have obtained a social security
number by visiting a local IRS office or by calling the IRS toll free at 1800-829-1040. Once
notified, the IRS will merge the taxpayer's ITIN and social security numbers into one account.
FURLONG: Joe, thanks. I think that's very helpful information. MCCARTHY: Okay. FURLONG: So, we
mentioned earlier that the deduction for personal exemptions has been suspended for tax years
beginning in 2018 through 2025 and that was affected by the Tax Cuts and Jobs Act, or tax
reform. This means that spouses and dependents residing outside of the United States who would
have been claimed as personal or dependency exemptions should not renew their ITINs this year
unless they are either filing their own tax return or they qualify for an allowable tax benefit.
So, for example, let's say you have dependent parent who meets certain qualifications to qualify
the primary taxpayer to claim head of household filing status, or possibly a spouse or dependent
qualified for the American opportunity tax credit or the premium tax credit. In these specific
cases, a federal tax return with the appropriate schedule or form that qualifies for that
allowable tax benefit, that must be attached to the renewable W-7 application to renew one's
ITIN. So, Philip, I think we may be ready for our second polling question. YAMALIS: Richard, I
think you're correct. That sounds great. OK. Our second polling question is on the screen.
Which taxpayers should not renew their ITINs? Which taxpayers should not renew their ITINs? A)
Is it taxpayers who are eligible for a social security number and expect to file a tax federal
tax return in 2020? Is it b) the spouse and dependents with ITINs who reside outside the United
States and do not qualify for a tax benefit under tax reform? Or is it c) taxpayers who receive
a CP 48 in the mail in 2019? Or is it d) the middle digits of their ITINs are 83, 84, 85, 86 or
87? Please take a minute, review the question again. Which taxpayers should not renew their
ITINs? Simply click on radio button that you believe most closely answers this question. We'll
give everyone just a few more seconds to make your selection. OK. Let's go ahead and stop the
polling now. We'll share the correct answer on the next slide. And drum roll, please. The
correct response is b, spouses and dependents with ITINs who reside outside the United States
and do not qualify for a tax benefit under tax reform should not renew their ITINs. I see that
about 81 percent of you responded correctly. That's a good response rate. Joe, I'm going to
turn it back to you. I've gotten some comments where we need your mic just a little closer to
your face there. And so, at this point, let's go ahead and turn it back over to you. YAMALIS: I
think Joe is in the room. He was last time I looked. MCCARTHY: Yes, I am here. YAMALIS: There
you go. MCCARTHY: OK. So, you can hear me. Am I loud enough now? YAMALIS: I think we are
hearing you loud and clear. Thanks, Joe. MCCARTHY: OK. I will continue to speak up then. To
renew their ITINs, taxpayers should complete the latest version of Form W-7 titled "Application
for Individual Taxpayer Identification Number" which is available on irs.gov or the IRS web site.
Taxpayers need to ensure they've checked the box on the W-7 that says, "Renewing an Existing ITIN"
and submit all of the required documentation including original documents or certified copies of
documents from the issuing agency along with the W-7. Now, be aware that notarized copies, which
are copies notarized by a notary public cannot be used as supporting documentation in a W-7
package submission. All documentation must be submitted must be consistent with the
applications information provided on the Form W-7. So, for example, if you had a name change due
to marriage or divorce, you must attach a copy of your marriage certificate or divorce
certificate to verify the name change. Generally, if a taxpayer if renewing an existing ITIN,
they may submit the form W-7, renewal application, without attaching a tax return. However, if
renewing a spouse or a dependent who resides outside the United States who are claiming an
allowable tax benefit, then they must attach a federal tax return to the W-7. Also, it's
important to note that all family members associated with a single tax return can renew their
ITINs at the same time if at least one of the family members' ITINs is expiring. Rich, do you
want to take the next slide? FURLONG: Sure, Joe. So, let's get into the nuts and bolts and your
options to submit a W-7 application for renewal of an ITIN. Now, your first option is by mail.
Taxpayers can renew their ITIN by mailing the form W-7 and the required documentation directly
to the Internal Revenue Service. The processing time if you submit it by mail is usually between
7 and 11 weeks. It is important to remember that original or certified copies of documents and
they will be certified from the issuing agency and these if they are submitted with the W-7
application, these will be returned to the applicant within 60 days. Taxpayers can call the IRS
if they had not received their original documents back within that 60-day timeframe. Now, the
alternative to mailing the W-7 documents directly to the IRS is that a taxpayer can visit an IRS
designated taxpayer assistance center in person. Certain designated IRS taxpayer assistance
center locations can then review the Form W-7, they can authenticate all original and certified
copies of documents both for the primary and any secondary taxpayers. And they can review the
passports, national identification cards and birth certificates for the dependents. MCCARTHY:
Rich, Can I interrupt and ask a quick question? FURLONG: Certainly. MCCARTHY: Can people just
walk into any IRS taxpayer assistance center to renew their ITIN? FURLONG: Unfortunately, not,
Joe. These days all individuals coming to an IRS taxpayer assistance center must make an
appointment. Now, I want to keep in mind everyone to keep in mind that, again, it has to be a
designated IRS taxpayer assistance center that has the resources, the trained staff and the
equipment to verify the documents and the W-7 application. For those taxpayers wishing to go to a
designated taxpayer assistance center, they must schedule an appointment before visiting the IRS
taxpayer assistance center. You may want to write down the phone number or you can see it on the
slide there. It is 844-545-5640. Now, if you want to find out which IRS taxpayer assistance
centers around the United States provide the ITIN application services, simply go to our IRS web
site and search under "Taxpayer assistance centers" and you can see a list of specific services.
I believe you have to search by zip code. Now, the final option and this is one we will discuss
in greater depth later um, is visiting a authorized certifying acceptance agent or CAA. Now,
because many of those attending today may not be familiar, or even have heard about certifying
acceptance agents, we will discuss them a bit more later in the presentation. So, now, let's
transition to talk about some common W-7 errors we see at the IRS that can cause processing
delays of the application. So, with that, let me turn it back over to you Joe. MCCARTHY:
Thanks, Rich. Let's talk about some common errors made when filing an ITIN application that
cause Form W-7 processing delays. The most common reasons for causing some delays are the box
"Reason for Submitting Form W-7" is not checked or the wrong box for "Reason for Submitting Form
W-7" is checked. Also, taxpayers are not submitting the required original identification
documents or certified copies from the issuing agency, along with their form W-7. In addition,
taxpayers are not submitting the required documents for proof of residency for dependents; and
finally, some taxpayers are submitting federal tax returns with expired ITINs. Now, what happens
if you submit a tax return with an expired ITIN? Well, it's not the end of the world. The tax
return file with an expired ITIN will be processed and treated as a timely file return, but it
will be processed without certain tax grants or benefits which may result in a in a decreased
refund or a balance due. However, once the ITIN is renewed, any exemptions and/or credits
previously disallowed will be reconsidered at that time. But until the ITIN is renewed, the
taxpayer will be subject to interest and penalties for any tax due and owing as a result of a
disallowed exemptions in credits. Phil, I think it's a great time for another polling question.
YAMALIS: Well, Joseph, I have to agree with you. We are receiving some comments from the
audience that some of you are not getting the polling questions. So, please, please take some
time now to disable your pop-up blocker so that you can see and answer the questions.
Additionally, if you haven't already done so, this is a good time to download the Form W-7 from
the materials section on the left side of your screen. I have it on good authority that you
might need it after this polling question. So, here's our third polling question. Which one of
these will cause a delay in processing an ITIN application or a renewal? Is it a) accurately
completing Form W-7 and attaching original documents or certified copies of required documents?
Is it b) submitting a complete application to a certified acceptance agent? Is it c) attaching
notarized copies of documents through the Form W-7 submitted to the IRS? Or is it d) scheduling
an appointment at the designated IRS Taxpayer assistance centers? Which one of these will
definitely cause a delay in processing an ITIN application or renewal? Please take a minute.
Review the question again and the answers. Click in the radio button that you most closely
what you believe most closely answers this particular question. We'll give everyone just a few
more seconds to make your selection. Go for it. OK. With that, let's go ahead and stop the
polling. Now Let's share the correct answer on the next slide. And the correct response is C.
How many of you got it? Yep, if we attach notarized copies instead of the original documents to
the Form W-7 submitted to the IRS, that would not be acceptable, and it will probably cause a
delay in processing the ITIN application or renewal. What do we got? Seventy-eight percent of
you responded correctly. So, what's going on? What do you think? Rich, Joe, one of you want
to clarify that answer for us? MCCARTHY: I tried, but why don't you help me out here? FURLONG:
Joe, this is Rich. Yes, a number of years ago, we tightened up the ITIN application process and
we no longer permit third party notaries to authorized that these are valid documents. And the
reason for that is that we have seen numerous instances where documents that looked valid based
on a review by forensic equipment that we use in the taxpayer assistance centers, or which is
used by the certifying acceptance agents, shows that they are not valid. So, we don't want
applications going down to the ITIN unit with notarized copies because we cannot authenticate
them. Only original documents are certified by the issuing agency are acceptable, Phil.
YAMALIS: Thank you, Richard. Appreciate that clarification. It really does help. So, since
you did clarify that, it looks like you're going to show us where some of the common errors are
made on the W-7 that are submitted to us. So, is that correct? FURLONG: Yes, I am, Phil. And
this is a very important part of this session because you have to make sure that the W-7
application is complete and correct before submitting it to the Austin processing center. So, one
of the most common errors that we see at IRS are for individuals not checking one of those reason
boxes and you see them highlighted with the red bar, A through H. Or another common error is
checking the wrong reason box when submitting a W-7. Let me give you an example. So, let's say
you check box B, a non-resident alien filing a U.S. federal tax return when actually based on
the number of days that you're present in the U.S. under U.S. tax law you would be considered a
resident alien and you should have filed checked the box C. Now, I'm going to turn it over to
Joe to discuss another common submission error that we see with the W-7 applications. MCCARTHY:
Thanks, Rich. FURLONG: Joe? MCCARTHY: I'm right here. I'm here, a little bit delayed. Not
submitting FURLONG: There we go. MCCARTHY: original identification documents or certified
copies from the issuing agency, along with the Form W-7 ITIN application is another common error
that causes delays in obtaining or renewing an ITIN; for example, not submitting a passport,
birth certificate, driver's license et cetera. It's also important to note that only a passport
with a U.S. entry date is acceptable as a standalone identification document for some
dependents. In addition, not submitting documentation of a name change, be it from a marriage or
divorce et cetera is another common error. Or not submitting documentations to prove residency
which can include U.S. medical or school records or dependents under age 6, U.S. school records
for dependents age 6 and over the underage 18, and U.S. school records if a student or rental
statements, bank statements or utility bills listing the applicant's name and U.S. address if
over age 18. FURLONG: So, Joe, when I look at those documents require, am I correct that if you
use either a certifying acceptance agent or you make an appointment to visit an IRS designated
taxpayer assistance center, then the applicant might not have to actually mail in the original
documents or at least some of these documents to the IRS. Am I right about that? MCCARTHY:
Rich, you are correct on that particular point. Yes, they don't have to mail it in. Some of
the they may not be required to mail all the documents if they use a certifying acceptance
agent or go to IRS taxpayer assistance center. FURLONG: So, that's very useful information to
know. And I think, Joe, on our next slide we have a list of documents that might be required to
be submitted along with the Form W-7. MCCARTHY: OK, let me turn it over to you then, Rich.
FURLONG: Great. So, the screen that you're looking at now is a snapshot of a portion of a table
from page three of the Form W-7 instructions. And I want to emphasize that we've revised the W-7
instructions and the only version of the instructions you want to use are the September 2019
revisions which are available on irs.gov. Now, this is a very important chart because it shows
both the acceptable types of documentation that can be used to established both foreign status
and the applicant's identity, identity as required by the W-7 form. Now, for those of you who
might be unfamiliar with the term "foreign status", foreign status is how the IRS establishes
that the applicant's connection is to a foreign country. Now, there are 13 acceptable documents
as shown on the full table, again, on page three of the W-7 instructions. One thing to keep in
mind though is that a valid unexpired passport, that is the only standalone document that can be
used to prove both one's identity and one's foreign status. If one submits an original passport
or a certified copy of a passport from the issuing agency, then that applicant does not need to
submit any other documents from the table in the W-7 instructions. However, if a passport is not
provided, then the applicants must submit at least two other current documents and one of those
documents must obtain must contain, excuse me a photograph, the only exception being a
dependent under the age of 14 or a student under the age of 18. If the applicant is either a
dependent under the age of 14 or a student under the age of 18, then one of the two documents
submitted must be a civil birth certificate from the home country. In addition, applicants
claimed as dependents must also either prove the U.S. residency unless the applicant is from the
two countries contiguous to the U.S., that would be Mexico and Canada, or possibly the applicant
is a dependent of a U.S. military personnel stationed overseas. And as we previously mentioned,
only supporting original supporting documents or, again, certified copies of supporting
documents from the agency that issued those documents must be submitted to the IRS with the
entire W-7 package. MCCARTHY: Now, Rich, does this slide show all the supporting documentation
that can be used to establish foreign status and identity when applying for an ITIN? FURLONG:
No, it doesn't Joe. It only shows what is it six of them. There are 13 types of documents.
Again, I would refer you to the form excuse me the instructions for the Form W-7 and those
instructions were revised in September of 2019. Now I'd like to switch gears a little bit and talk
about certifying acceptance agents or CAAs. Certifying acceptance agents help the IRS by
facilitating the IRS the IRS ITIN application process and they do this in a number of ways.
They verify both the foreign status and the identity of the applicants. They authenticate the
documents provided by the taxpayer. And finally, CAAs complete and submit Form W-7, along with
any required documents and the underlying tax returns directly to the Internal Revenue Service.
Now, the certifying acceptance agents, or CAAs, they must meet with the taxpayers and conduct
interviews. However, these interviews may either be face to face or these days the CAA could
use virtual technology, such as Skype or some sort of live meeting to determine ITIN eligibility.
However, even if they're conducting a virtual interview, the CAA must have in their possession
the original or certified copies of the documents in hand during that interview. Using the CAA
allows taxpayers to keep their original documents instead of submitting them to the IRS. So,
that's a real benefit for the applicants. Another benefit is that certifying acceptance agents
also receive copies of ITIN notices and CAAs have a direct telephone number to the ITIN operation
unit which is located in Austin, Texas and that can help resolve any ITIN processing issues.
Now, a certifying acceptance agent can be one affiliated with, for example, an educational
institution; it could be a financial institution, perhaps a government entity or military base.
It could be certain community-based organizations in a particular locality that has a high
number of individuals who might need an ITIN. And finally, and Joe and I know there are many tax
practitioners attending today, tax practitioners may find it beneficial as part of their
practice to become CAAs. However, keep in mind that a certified acceptance agent may charge a
fee for their services. So, how do we find a certifying acceptance agent? Well, it's pretty
easy. Just go to irs.gov, search "CAA" or certifying acceptance agent on our web site and you
can find a list of them. I think they're broken out both in by state and also abroad because
there are CAAs elsewhere outside the United States. And for those of you attending today who may
be interested in becoming certifying acceptance agents, we'd like to remind you that the IRS is
actively recruiting CAAs. And we're doing this because, by increasing the availability of the
ITIN services provided by CAAs nationwide, it's particularly helpful to those in communities
with high ITIN usage. So, if any of you attending today are interested in becoming a certified
acceptance agent, please again visit our web site, irs.gov, and search under
www.irs.gov/itinagent or go to the IRS and we have a Publication 4393, "What is an IRS Certifying
Acceptance Agent". And we also have the longer publication which is available on the web site,
Publication 4520, "Acceptance Agent's Guide for an Individual Tax Identification Number". These
are great resources to help you fully understand the CAA program. And, Philip, I think we're now
ready for our if I'm not mistaken our fourth and final polling question. YAMALIS: Rich, we
are. Thank you. Man, you and Joe are so full of knowledge. I appreciate it, appreciate it a
lot. So, audience, let's go ahead and look at our final polling question. And that question is
on the slide. It reads, which statement is not true with regard to the certifying acceptance
agents, otherwise known as CAAs? So, which of these is not true? A) CAAs are certified by the
United States Citizenship and Immigration Services, b) The CAAs may receive copies of IRS ITIN
notices and they can respond to the ITIN operation. Is it c) IRS continues to recruit new CAAs
to expand availability of those services around the United States? Or is it d) CAA's facilitate
the ITIN application process for both applicants and the IRS? Now, folks, tell me, which statement
is not true with regard to certified acceptance agents? We need to see at least a 95 percent
right here. Come on. I know we can do it. Take a minute and review the question again. Go
ahead and click on the radio button that you believe most closely answers this question. Looks
like we have a mic that's running away from the table here. We'll give everyone just a few more
seconds to make your selection. And I apologize for the technical difficulties we're having. I
know I hear it in my background here. That is not happening with any of our speakers here, so
hopefully our producers can rectify where that noise is coming from. OK. Let's go ahead and stop
the polling on this final polling question that show the correct answer on the next slide. And
there it is. The correct response is a) CAAs are not certified by U.S. Citizenship and
Immigration Services. But, of course, they are certified by the Internal Revenue Service. All
right. Let's see how it went. Eighty percent. OK. Eighty percent of you responded correctly.
That's a decent response rate. I was hoping for a little bit of a higher response rate, but
let's go ahead and move on. Rich, I believe that you have some excellent resources to share with
our audience more than you already presented to us thus far, so let me turn it over to you.
FURLONG: Thanks, Philip. Yes, the IRS, in my humble opinion, does have some excellent resources
online for anyone interested in learning more about the ITIN program and the certifying
acceptance agents. So, as you can see in the slide, start with the ITIN homepage and you have the
web address there. We have several sets of FAQs and I found them very beneficial when I've
gotten specific questions from the public on ITINs. So, you can search under ITIN expiration
frequently asked questions. And then, we have a separate set of questions on the ITIN process.
Again, for those attending today who are interested in becoming an acceptance agent or a
certifying acceptance agent, you see the link there. You can search under CAA. And you see the
Publication 4393, which is both in English and Spanish. I mentioned that. And I'll give another
pitch for the Publication 4520, the "Acceptance Agent's Guide to the Individual Taxpayer
Identification Number". And, of course, we would remiss if we didn't mention again the Form W-7,
instructions for the W-7. And one final publication, it's an electronic pub. You may want to
write this number down, Publication 1915, "Understanding Your IRS Individual Taxpayer
Identification Number". It's a great resource. So, Philip, let me turn it back over to you.
YAMALIS: Thanks, Richard. Appreciate it. OK. It's me again. It's Philip Yamalis. I'll be
moderating today's question and answer session. Before we start today's Q&A session, I want to
thank everyone for attending today's presentation, Understanding Individual Taxpayer
Identification Numbers. Now, earlier, I mentioned to you that we want to know what questions you
have for our presenters. So, here is your opportunity if you haven't already done so. If you
haven't already put those questions, there is still some time. Go ahead. Click on the "Ask"
question button. Type in your question and simply click "Submit". Again, no specific taxpayer
information in that comment box when you submit that question; please, please, please. So, Joe
McCarthy and Rich Furlong, who presented an excellent presentation today to us are staying on
with us and will be answering your questions. We thought we were going to have Sharon Bradley
from our operations our ITIN operations join us, but unfortunately, she is unable to join us
for our Q&A session today. So, we apologize about that, but I have all the confidence in the
world in Joe and Rich. One thing before we start, we may not have time and we probably will not
have time to answer all the questions submitted. However, let me assure you that we are going to
answer as many as time allows. If you're just as a reminder, if you're participating to earn a
certificate and related continuing education credit, you will qualify for one credit by
participating for at least 50 minutes from the official start time of the webinar, which means
the first few minutes of chatting and technical stuff that I went through before the top of the
hour, that does not count towards that 50 minutes. Sorry. OK. Joe, Rich, I hope you're ready.
I know we've received quite a few questions, so let's get started so we can get to as many of
these questions as possible. And let me start with you, Richard. So, here is a very important
question that came in. I only use my ITIN on information return like Forms 1099 and the like.
If my ITIN is expiring, do I need to renew it? FURLONG: That's a great question, Phil, because
it's one we've heard before and it really comes back to the key point here as to whether or not
you are required to file a U.S. federal tax return. As we know, information returns, one of them
is a 1099. And you would only, and you could get an ITIN or you could get excuse me receive
an information return with an ITIN. But if you are not filing a U.S. federal tax return or
making a claim for refund on a U.S. federal tax return, then you do not need to renew your ITIN.
And whether or not you have to file a federal tax return would be dependent on a number of
technical factors which we don't go into today are you a U.S.-resident alien for tax purposes,
are you a U.S. non-resident alien. Phil, I, for filing requirements for non-resident aliens, I
always point the individual to IRS Publication 519 on U.S. Tax Guide for Aliens. But long story
short, if you're not required to file a federal tax return or filing to claim a refund of any
tax withheld, then you should not renew your ITIN that circumstance, Phil. YAMALIS: OK, Rich,
thank you. Let me ask you another one here that came to us. And we appreciate the question. I
think it's a good one. How could a foreign person living abroad who wants to form a sole member
LLC or C corporation how can they obtain an ITIN? FURLONG: So, I saw this question come in while I was
listening to Joe and I'm glad we're getting to it because it involves a number of factors here.
Now, it involves both not only the ITIN process, but also obtaining the U.S. tax
identification number for a business whether it's an entity such as a C corporation which I
think the questioner asked about or something called a sole-member LLC. So, the application to
obtain a EIN, employer identification number, for an entity is made, of course, as I think most
folks know on the call today, via Form SS4. If you are making that application though, you
would already need to have an ITIN if you are the sole responsible person for that entity because
otherwise, they would not process the SS4 application. So, to do that, I would refer you back to
the Form W-7 which is the starting point to get the ITIN and direct the caller and then the
other individuals to look closely at reason number h, other or not number, reason h in
the top of the W-7 application and look at the instructions. And you might want to use a
certifying acceptance agent if you're abroad to facilitate that process, Phil. So, you would
want to get the ITIN first before you submit the Form SS4. YAMALIS: Very good. Loaded question
and you handled that quite well. Thank you. Richard, let me throw another one at you. How
long will a return be delayed in processing if it's filed with an expired ITIN? I know Joe went
over some of those, but I want to throw that question at you. FURLONG: Sure. So, we do see that
on occasion. We have a take return come in with an ITIN, but that ITIN has expired under the
program. So, that return will be processed, and we will still treat it as timely filed. However,
and this is a very important however that tax return will be processed without
certain tax credits and/or claimed exemptions if it's a prior-year return and no refund will be
paid at that time. So, when we get that return with the expired ITIN, the taxpayer then receives
a notice from the IRS explaining the reason for the delay in processing any refund and explaining
to the taxpayer that the ITIN must be renewed. And once that ITIN is renewed, any exemptions in
credits will be processed and then the allowable refund under tax federal tax law will be
paid. If the ITIN is not renewed, the taxpayer could be subject to interests and penalties for
any tax owed as a result of any additional added exemptions or credits. So, that goes to
the point, Phil, you want to make sure you renew your ITIN, if at all possible, before filing a
tax return. YAMALIS: You got to avoid those delays. Anything to avoid delays, I'm all for it.
Thanks. So, Joe, let me turn it over to you since we're talking about delays and know that we
have to renew our ITIN if it's issued prior to 2013, we have somebody that submitted a
question that they're not sure when I got my ITIN, how do I know if it was issued prior to
2013? Joe? MCCARTHY: You, you're going to know that your ITIN was issued prior to 2013 by the
middle two digits of the ITIN. So, YAMALIS: Right. MCCARTHY: the ITINs that
have middle digits between 70 and 87 were all issued prior to 2013 and are now all of them are
now expired. So, ITINs with the middle digits of 70 through 87 must be renewed when filing a tax
return in 2020. And when renewing an ITIN issued prior to 2013, you'll be issued a new ITIN
number. YAMALIS: Excellent. Thank you for that concise answer. So, we have an audience member
that says, Joe, I'm confused. On the IRS web site, they list acceptance agents and they list
certifying acceptance agents. What's the difference between the two, Joe? MCCARTHY: Well,
that's easy to get confused especially since the names are so similar. Both certifying
acceptance agents and acceptance agents can prepare and submit Form W-7s along with required
documents to the IRS. However, and this is a big however only certifying acceptance agents
are allowed to certify that they have reviewed and verified the original documentation or
certified copy from an issuing agency. So, for example, if you don't want to send in your passport
to the IRS, make sure you use a certifying acceptance agent and not an acceptance agent when
applying for or renewing your ITIN. And there's only a smattering of acceptance agents out there
that, if you go on to the IRS web site, do make sure that you know the difference between a
certifying acceptance agent and an acceptance agent. YAMALIS: So, let me just ask a follow up to
that. For some of those MCCARTHY: Sure. YAMALIS: that are accepting agents that want to
become certified, do we explain that process pretty easily for them? MCCARTHY: Well, I would
refer them to that Publication 4393 or to go the web site, the web link that Rich talked about
and it was irs.gov/ITINagents. And that gives you an explanation of how to become a certifying
acceptance agent. YAMALIS: There you go. OK. Thanks, Joe. And let me throw one more at you.
So, we talked about, you know, having a valid ITIN. Now, all of a sudden, accepted I become a
resident and I'm now eligible for an SSN so I can go to work. So, but I have a valid ITIN. I'm
eligible for a social security number. Do what happens? What happens to that ITIN? Do I
do I have to apply a for social security number once I'm eligible for it? Of course, right? But
MCCARTHY: Yes. YAMALIS: what happens to that ITIN? MCCARTHY: OK. So, let's say you have an
ITIN and then you apply for a social security number and you're issued a social security number
by the Social Security Administration. What you would do is you will contact the IRS in order to
get the social security number account and your ITIN account merged into one account. And in
order to do that, you can you have one or two things, you can go to an IRS taxpayer assistance
center, you have to call them and ask you make an appointment, then go there and they will take
your information and then merge those two accounts or you can call the IRS. And it's the normal
1-800-829-1040 number in order to make the IRS aware of the new social security number that
you've been issued, and they will merge the two accounts together. YAMALIS: Excellent. Excellent
MCCARTHY: And I just want to add one so, let me just add one more thing. So, going forward,
once you're issued that social security number, you would use that social security number when
you're filing your tax returns. YAMALIS: Very good very good. So, it makes sense to get those
merged right away to avoid processing delays in the future, of course. MCCARTHY: Absolutely.
YAMALIS: All right, Rich. Let me turn it over to you. There seems to be some interest in the
requirements to become a certified acceptance agent. So, this particular person was not aware
of this program prior to today's webinar and the excellent resources that you gave us, and they
can see how it may be a new service to offer their clients in their ) city. So, once again,
please review the requirements to become a CAA for our audience today. FURLONG: Well, thanks,
Phil. And that is gratifying that well, I think we may have peaked your interest in this
important program of the certifying acceptance agent. So, there are four major steps that one
may take, and these are directly from the Publication 4393 that Joe and I have referred to several
times today. First, you're going to have to take some mandatory training because we want to make
sure you understand your responsibilities and have the tools to authenticate information and
correctly complete the W-7 on behalf of the client. Now, this training is strictly online, and you
can go to irs.gov and, in fact, you can open up the Publication 4393 and click over to a fairly
detailed online PowerPoint presentation which you go through. It's very comprehensive, very good
actually. And I would suggest having the W-7 side by side and the instructions and you could go
through that. Then, you have to submit an application, no surprise there. So, it's Form 13551,
"Application to Participate in the IRS Acceptance Agent Program". And certain individuals may be
required to submit fingerprint cards. Now, if you're an electronic return originator, you do not
have to submit. And currently, in the ERO program, you do not have to submit fingerprint cards.
Now, there's a second type of training and that is mandatory ITIN Acceptance Training, well
that's the certification. So, you've taken an online training, you certify on the Form 13551.
And then, the second type of training and this may intrigue some of you is what we call,
Forensic Documentation Identification Training. You may recall that I said that we have seen
numerous instances of fraudulent documents being submitted as part of the ITIN program. So, you
can go to irs.gov, www.irs.gov/forensic to get more information on the third-party vendors who
provide forensic documentation document identification training program. So, those are the
basic four requirements, Phil, and they're all in Publication 4393. YAMALIS: Excellent, Rich.
Thank you so much. Now, it is the top of the hour. So, I know, audience, that we scheduled for
60 minutes but we've been told by our producers that since we have an abundance of questions,
we're going to stay on just a bit longer to try to answer more of these questions. So, if you
could stay with us, we certainly would encourage that and that would be great. So, let me ask a
follow-up question to that, Rich. What process what can an acceptance agent use to follow for
sudden changes in procedures? I know a lot of our folks are subscribed to e-News for
Tax Professionals. What can an acceptance agent follow to get sudden changes of procedures? Is
there anything that you could recommend? FURLONG: Well, we'd like not to thanks, Phil. We'd
like not to have I don't think there are sudden changes, but there have been some significant
changes in the past, say, 8 years to 10 years, one of them being the initiation of the certification process. I would suggest subscribing to the e-News for Tax Professionals. I
think that's the best source. I'm not aware of any specific online publication. But I do know
that on occasion, specific IRS online publication directed the periodical directed towards
CAAs. But I do know that, periodically, I've seen in the weekly, every Friday, the e-News for
Tax Professionals is dropped into one's mailbox if you subscribe. And occasionally, there are
articles there on changes. And then, of course, when we have a significant change, it would be
announced most probably, Phil, by a news release. So, if you subscribed to IRS News Wire, you
would get an announcement of a significant change that might have involved in it a change
involving some sort of legal guidance such as a notice or a Rev Proc. So, those are my
suggestions today to keep abreast to the program. YAMALIS: Of course. And as Stakeholder
Liaisons we always like to do a commercial on e-News for Tax Professionals. So, that was an
excellent question. A lot of us can do that. So, let me turn it over to you, Joe. There's a
question here that says, I want to know if it's still correct to send the, the 2019 1040, the,
whoa, let me say that again is it still correct, as in the past, to send the 1040 for 2019
together with the W-7 and all the documents? Could they be sent together? MCCARTHY: Yes, they
can. They can be sent together. The only thing that I would remind the person who's submitting
it is not to submit the 1040 to the address that's located in the 1040 instructions, rather they
would submit that W-7 with the supporting documentation and the tax return to the address
located in the W-7 instructions. That's very, very important to note. But yes, still you can
still submit the application for an ITIN along with your tax return. But just be aware that if
you're just renewing if you're if you're renewing and you're living inside in the United
States, you can renew your ITIN without filing a tax return. But you need to have first, you
need a tax return when you're applying for an ITIN or if you have a dependent or a spouse living
outside the United States and claiming a tax benefit, then you have to file that return along
with the W-7 and the supporting documentation. YAMALIS: Excellent. Excellent. So, let me ask you
and it's not a follow up because you threw the follow up in there and I appreciate that.
Another question. Could you please repeat what to do when an ITIN holder changes their name
because of marriage or divorce? How do they get that rectified? MCCARTHY: When that happens,
when you let's say, you get married, when you're submitting your renewal, if the information
on the W-7 does not match the, the information that you're submitting, let's say, your passport
has one name and your W-7 has a different name because you got married in interim, you want to
attach a marriage certificate along with the W-7. That's one of those documents that you send
in. YAMALIS: Uh huh. Joe, let me throw this question at you because I believe that it should be
pretty clear after this webinar. Do persons with ITIN pay into social security and do they have
taxes withheld? MCCARTHY: OK. If you're an ITIN holder, you having an ITIN does not allow you
to work in the United States. So, in theory, you should not be working in the United States and you wouldn't receive a W-2. So, that kind of negates the whole purpose of people coming to the
United States and working with an ITIN. They're really that ITIN does not make you legal to
work in the United States and, as such, you really shouldn't have a filing requirement. FURLONG:
Hey, Joe? YAMALIS: Excellent, Joe. MCCARTHY: Yes? FURLONG: Can I just MCCARTHY: (INAUDIBLE),
Rich? FURLONG: Yes. I just because in the reality here is that we do see both individuals not
eligible for social security number either having somebody else's social security number on a W-2
and that's a version of employment-related tax identity theft or, on occasion, I have seen ITINs
on a W-2. And there are taxes taken out to their maybe social security Medicare and then maybe
federal income tax withholding by an individual who perhaps is not legally authorized to work in
the U.S., but is working, being paid, getting a W-2 and having taxes taken out. And they very
well could have a filing requirement in that case based on a number of factors that we won't get
into, they could be a U.S. resident alien for tax purposes or a non-resident. The downside
is and you sort of touched on this, Joe, they won't get credit for any of on the social
security records because they don't have a social security number to track the period of time
they're working under that ITIN. So, it's an unfortunate circumstance, but it does occur and we do
see individuals who, in some cases, are undocumented complying with the U.S. federal tax filing
responsibilities by obtaining an ITIN because we're not standing in the shoes of immigration,
we're just we need ITINs to process tax returns and to apply payments for those who are
required to U.S. federal tax returns. So, we do see that, but they won't get social security
credit if they don't have a social security number. YAMALIS: Excellent insight, Rich. And our
producers are giving me the look. So, let me just throw this last question at you. Do you know
when the newest version of the W-7 will be made available and, if not, how can we find out?
FURLONG: Well, it's sort of past tense. It was made available in August of 2019 which is only
about six months ago. So, the newest version of the W-7 is August 2019 and the newest version
of the instructions, which came out a month later, September of 2019. And in the new version of
the instructions, they referenced some of those significant changes that Joe discussed as a as
a result of tax law change and who might not have to renew an ITIN. So, we strongly advise
reviewing those latest editions of the W-7 and the instructions, Phil. YAMALIS: So, those
versions that are posted to the website, to the irs.gov website are the current the current
revisions? FURLONG: They are indeed. YAMALIS: Excellent. You guys, thank you so much. I am
getting the look from the producers. I wish I can be here all day for you. That's really all
the time we have for questions. So, again, thank you, Joe McCarthy, Rich Furlong for sharing
your knowledge with us, with sharing your expertise and also answering some of our questions
submitted to us by the audience. Before we close the Q&A session today, Rich or Joe, what key
points do you want the attendees to remember from today's webinar? FURLONG: OK. Phil, I'll take
that. So, the key points or several of the key points we want you to take away, just to renew
review the point we just made please review carefully the most recent version of the W-7 form,
that's the August 2019 version, and the instructions which were released in September of 2019
before renewing your ITIN. Make sure only either original documents or certified copies from the
issuing agency are submitted with the W-7 when required to do so. Again, remember, as a result
of tax reform that a deduction for personal exemptions, that has been suspended for tax years
2018 through 2025 and as a result, some individuals may not have to renew ITINs this year. And
finally, as Joe mentioned, all ITINs issued prior to 2013, they have now expired. So, Phil, let
me turn it back over to you to wrap it up. YAMALIS: Thank you, Richard. We appreciate it.
Ladies and gentlemen, we are definitely planning additional webinars for this year. So, to
register for an upcoming webinar, please, visit us at irs.gov, use the keyword, search as
"webinars". Select the webinars for tax practitioners or webinars for small businesses. We
will be offering certificates and CE credit for other upcoming webinars. Once again, you can
visit the IRS video portal at www.irsvideos.gov. We do want to remind you; however, continuing
education credits or certificates of completion are not offered if you view an archived version
of any of our webinars on the IRS video portal. Again, a big thank you to Joe and Rich for such a
great webinar today. I also want to thank you, our attendees, for attending today's webinar,
Understanding Individual Taxpayer Identification Numbers. If you attended today's webinar for at
least 50, that's 5-0 minutes, after the official start time, you will receive a certificate of
completion that you may use with your credentialing organization for one possible CPE credit. If
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Again, ladies and gentlemen, it has truly been a pleasure to be here with you today. And on
behalf of the Internal Revenue Service and our presenters, Rich Furlong, Joe McCarthy, we would
like to thank you for attending today's webinar. It is really important for the Internal Revenue
Service to stay connected with the tax professional community with industry associations, with
federal, state and local governments organizations as well as individual tax payers. You indeed
make our job a lot easier by sharing the information that allows for proper tax reporting.
Thanks again for your time and attendance today. And we indeed wish you much success in your
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