CAA CAA ITIN Renewal and Expiration Policies 2 — Questions and Answers
Question 1: Under the PATH Act of 2015, ITINs issued before 2013 are subject to what policy?
- Rolling expiration by middle digit group (Correct answer)
- Immediate expiration upon passage
- Expiration only if unused for 5 years
- Permanent validity
Correct answer: Rolling expiration by middle digit group
The PATH Act established a rolling expiration schedule for pre-2013 ITINs, expiring them in batches grouped by their middle digit numbers.
Question 2: What IRS notice does a taxpayer receive when their ITIN is about to expire?
- CP48 Notice (Correct answer)
- CP2000 Notice
- CP501 Notice
- Letter 4310C
Correct answer: CP48 Notice
The IRS sends CP48 notices to taxpayers whose ITINs are expiring, advising them to renew if they will need to file a federal tax return.
Question 3: When renewing an ITIN without attaching it to a tax return, what must accompany Form W-7?
- Supporting identification documents (Correct answer)
- Proof of all prior tax filings
- A signed authorization letter from the IRS
- A completed Form 1040 draft
Correct answer: Supporting identification documents
Even in a standalone renewal without an attached tax return, the applicant must still provide the required supporting identification documents with Form W-7.
Question 4: What is the IRS's estimated processing time for ITIN renewal applications submitted by mail during non-peak periods?
- 7 weeks (Correct answer)
- 2 weeks
- 30 days
- 90 days
Correct answer: 7 weeks
The IRS estimates approximately 7 weeks to process mailed ITIN renewal applications under normal, non-peak processing conditions.
Question 5: Which of the following is TRUE about ITIN renewal: does the IRS assign a new ITIN number upon successful renewal?
- No, the taxpayer keeps the same ITIN number (Correct answer)
- Yes, a new number is always issued
- Only if the original was issued before 2010
- Only if the taxpayer requests a new number
Correct answer: No, the taxpayer keeps the same ITIN number
When an ITIN is renewed, the taxpayer retains the same ITIN number — renewal reactivates the existing number rather than issuing a replacement.
Question 6: A taxpayer files their return before renewing an expired ITIN; what is the IRS's procedure in that situation?
- Process the return but hold certain credits until renewal is completed (Correct answer)
- Reject the return entirely
- Issue the full refund immediately without renewal
- Require the taxpayer to refile after renewal
Correct answer: Process the return but hold certain credits until renewal is completed
The IRS will process the return but hold refundable credits such as the ACTC and AOTC until the taxpayer successfully renews their ITIN.
Under the PATH Act of 2015, ITINs issued before 2013 are subject to what policy?