PwC’s Law firm services news alert: Recent developments on ITINs

June 27, 2017

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ITIN renewals for 2017

The IRS is now accepting renewal applications for the Individual Taxpayer Identification Numbers (an “ITIN”) that are set to expire at the end of 2017. Taxpayers are urged to file their ITIN renewal applications as soon as possible to avoid any end-of-year rush that may occur.

Who should renew an ITIN?

Taxpayers whose ITIN is expiring and who need to file a tax return in 2018 must submit a renewal application. Others do not need to take any action. All ITINs not used on a federal income tax return at least once for tax years 2014, 2015 or 2016, will expire on December 31, 2017.

ITINs with the middle digits 70, 71, 72, or 80 (For example: 9NN-70-NNNN; NNN-71-NNNN; 9NN-72-NNNN; 9NN-80-NNNN) need to be renewed even if the taxpayer has used it in the last three years. The IRS will begin sending the CP-48 Notice, You must renew your Individual Taxpayer Identification Number (ITIN) to file your U.S. tax return, later this summer to affected taxpayers. The notice explains the steps to take to renew the ITIN if it will be included on a U.S. tax return filed in 2018. Taxpayers who receive the notice after taking action to renew their ITIN do not need to take further action unless another family member is affected.

Obtaining ITINS for nonresident partners located outside the United States

U.S-based IRS-approved Certified Acceptance Agents (CAAs) are no longer required to submit IRS Form 15003, Attestation of Non-Resident Interviewed in the United States. This action, effective May 3, 2017, allows U.S. based CAAs to once again provide Individual Taxpayer Identification Number (ITIN) services to all applicants without additional form requirements.

As a reminder, CAAs are required to conduct a face-to-face interview with ITIN applicants to determine eligibility for the number. Those who use electronic video conferencing (e.g. Skype) to conduct the face-to-face interview with their clients must have original identification documents or certified copies from the issuing agency in their possession at the time of the interview.

Due to this change, PwC's CAAs are once again able to assist our law firm clients and process ITIN applications for law firm foreign nonresidents partners located outside of the United States. PwC's CAAs can meet with nonresidents when he or she is in the United States or when the CAA is traveling outside of the United States to the nonresident's location.

If you would like to discuss the 2017 ITIN Renewal process and/or having one of PwC's CAAs assist your nonresident partners in obtaining an ITIN, please contact us to start the conversation.

How PwC can help

PwC is a leading provider of audit, tax and advisory services to law firms based in the United States and abroad. Our national network of experienced professionals can assist firms with key planning opportunities including the annual audit, assurance services, partner and partnership tax, tax compliance and planning services, HR services, benchmarking, and disputes and investigations. In addition, our strong international network helps law firms address key global business issues.

Contact us

Gary M. Pogharian
Partner, PwC US
Tel: +1 (646) 471 7202

Karen LoDico
Partner, PwC US
Tel: +1 (267) 330 6266

Carole Symonds
Law Firm Services Tax Leader, PwC US
Tel: +1 (207) 232 6069

Gregg Sincoff
Managing Director, PwC US
Tel: +1 (646) 471 1335

Rob Cinberg
Tax Managing Director, PwC US
Tel: +1 (267) 330 6221

Nancy Regan
Director, PwC US
Tel: +1 (973) 236 5771

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