My NacuboWhy Join: Benefits of Membership

E-mail:   Password:   

 Remember Me? | Forgot password? | Need an online account?

Business and Policy Areas
Business and Policy Areas

New ITIN Procedures For Certifying Acceptance Agents and International Students

October 14, 2016

International students and other individuals who require individual taxpayer identification numbers (ITINs) to file their income tax returns have new procedures to follow, as of October 1. The IRS has issued two guidance documents explaining the changes. 

In August, the Internal Revenue Service (IRS) posted IR-2016-100, in which it explains the ITIN changes mandated by the Protecting Americans from Tax Hikes (PATH) Act, which was signed into law in December 2015. The release summarizes Notice 2016-48, which outlined PATH Act changes to the ITIN program.

The most significant changes will affect taxpayers with ITINs that haven't been used in the past three years or that were issued prior to 2013. Without action, individuals could experience delays in tax refunds and eligibility for certain tax credits.

International students or other individuals who do not need to file a 2017 tax return do not need to take any action at this time. However, two groups of individuals will need to renew their ITINs before filing their 2017 tax returns:

  • Filers with unused ITINs. ITINs not used on a federal income tax return in the last three years (covering 2013, 2014, or 2015) will no longer be valid to use on a tax return as of Jan. 1, 2017. ITIN holders in this group who need to file a tax return next year will need to renew their ITINs. The renewal period begins October 1.
  • Filers with expiring ITINs. ITINs issued before 2013 will begin expiring this year, and taxpayers will need to renew them on a rolling basis. The first ITINs that will expire under this schedule are those with middle digits of 78 and 79 (e.g., 9XX-78-XXXX). The renewal period for these ITINs also begins October 1. The IRS mailed letters to these taxpayers informing them of the requirement to renew their ITINs if they need to file a tax return and explaining steps they need to take. The IRS will announce the schedule for expiration and renewal of ITINs that do not have middle digits of 78 and 79 at a later date.

To renew an ITIN, an individual must submit a W-7 application package to the IRS. The package consists of Form W-7, Certificate of Accuracy for IRS Individual Identification Taxpayer Number, and numerous documents verifying the authenticity of the applicant. Taxpayers can submit their application package through a Certifying Acceptance Agent (CAA), by mail, or in person at a designated IRS service center.  Many colleges and universities serve as CAAs.  

The IRS is implementing several changes to the ITIN acceptance agent program in an effort to streamline processes. First, CAAs will now be permitted to authenticate the passport and birth certificate for dependents. CAAs will continue to certify identification documents for the primary and secondary applicants. Form W-7 must be attached to each Form W-7 application submitted as verification the CAA has reviewed the original documentation or certified copies from the agency that issued them. CAAs will have to attach and send copies of all documentation reviewed with the Form W-7 to the IRS.

Second, the IRS will now accept Form 13551, Application to Participate in the IRS Acceptance Agent Program, year-round, and the Service is actively recruiting CAAs.


Mary Bachinger
Director, Tax Policy