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The IRS has revised the instructions for Form W-7, “Application for IRS Individual Taxpayer Identification Number.” The revision provides that Certifying Acceptance Agents (CAAs) can verify original documentation and certified copies of items from the issuing agency for primary and secondary applicants and their dependents — with a newly added exception for foreign military identification cards.
CAA basics
Form W-7 is used to apply for an individual taxpayer identification number (ITIN), a tax processing number the IRS issues to people who can’t get a Social Security number. The applicant must submit documentation to the IRS to prove the applicant’s identity, among other things.
A CAA is a person authorized under an agreement with the IRS to submit a Form W-7 to the agency on behalf of an ITIN applicant without furnishing supporting documents. Instead, the CAA certifies to the IRS that it has reviewed the documentation of the applicant’s identity and alien status, and that it’s maintaining a record of that documentation. CAAs can use Form W-7 to certify that they have reviewed and verified the original documentation, or a certified copy of those documents from the issuing agency, through face-to-face or video interviews.
CAAs must have the original identification documents (or certified copies thereof) in their possession during the interview. Note that a certified copy is one that the original issuing agency provides and certifies as an exact copy of the original document and contains an official stamped seal from the agency.
September 2019 instructions provide that “a Certifying Acceptance Agent (CAA) can verify original documentation and certified copies of the documentation from the issuing agency for primary and secondary applicants and their dependents.”
What’s new
The IRS says that the sentence quoted above should now read: “A Certifying Acceptance Agent (CAA) can verify original documentation and certified copies of the documentation from the issuing agency for primary and secondary applicants and their dependents, except for [a] foreign military identification card.”
This change will be reflected in the next revision of the Instructions for Form W-7, which will be issued in 2020. It’s not clear whether this correction is a change from previous policy or merely an amplification of a pre-existing policy.
Contact Elliott Davis for more information on this and other matters related to doing business internationally.
The information provided in this communication is of a general nature and should not be considered professional advice. You should not act upon the information provided without obtaining specific professional advice. The information above is subject to change.
