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Individual Taxpayer Identification Number

The Individual Taxpayer Identification Number (ITIN) is a nine-digit processing number issued by the (IRS) to resident and nonresident aliens, their spouses, and dependents who must file U.S. federal returns or report income but are ineligible for a (SSN). ITINs begin with the numeral 9 and follow the format 9XX-XX-XXXX, serving exclusively as an identifier for administration purposes without authorizing , conferring immigration status changes, or entitling holders to Social Security benefits or credits like the . Established by the IRS on July 1, 1996, the ITIN program addressed gaps in tax compliance by providing a mechanism to track and collect federal taxes from individuals lacking SSNs, such as foreign nationals with U.S. tax obligations who could not otherwise be identified in IRS systems. Prior to its creation, the IRS struggled with processing returns from non-SSN holders, leading to incomplete tax administration; the ITIN enabled better enforcement of reporting requirements under U.S. for entities including nonresident aliens and certain dependents. Eligibility requires demonstrating a federal tax purpose, such as filing a U.S. tax return, and submitting Form W-7 alongside supporting identity and foreign status documentation, with applications processed via mail, IRS offices, or certified acceptance agents. ITINs expire if unused for federal tax filing over three consecutive years or upon reaching certain middle-digit thresholds (e.g., 70 through 88, effective post-2012), prompting renewal to prevent processing delays, though renewals do not retroactively validate prior filings. In response to documented instances of fraud and misuse—such as applications lacking genuine tax purposes—the IRS has tightened standards since 2012, including enhanced documentation verification and restrictions on exceptions, to align issuance strictly with tax administration needs rather than broader eligibility expansions.

Overview

Definition and Purpose

The Individual Taxpayer Identification Number (ITIN) is a nine-digit tax processing number issued by the (IRS) to individuals who are required to have a U.S. taxpayer identification number for federal tax purposes but are ineligible for a (SSN). It begins with the numeral 9 and follows the format XX-XXXXXXX, distinguishing it from SSNs and other employer identification numbers. The primary purpose of the ITIN is to enable compliance by allowing eligible individuals—such as certain nonresident aliens, their spouses, and dependents—to file U.S. returns and report accurately, even without an SSN. This facilitates efficient processing and accounting of returns from persons who otherwise lack a suitable identifier, ensuring the IRS can track obligations regardless of the filer's status. ITINs are issued only to those with a demonstrable filing requirement, such as nonresidents earning U.S.-sourced or dependents claimed on returns by U.S. taxpayers. Unlike SSNs, ITINs serve solely as a administration tool and do not confer eligibility for Social Security benefits, employment authorization, or other federal programs. They are not valid for employment-related reporting, where an SSN or other work-authorized identifier is required, underscoring their limited scope to reporting and refund processing. This distinction prevents misuse while promoting revenue collection from taxable activities involving non-SSN holders.

Eligibility Criteria

The Individual Taxpayer Identification Number (ITIN) is available to individuals ineligible for a (SSN) who must comply with U.S. tax reporting requirements. Eligibility requires a demonstrable tax purpose, such as filing a U.S. , claiming a refund or allowable , or being included on a to support specific benefits. Applications must accompany a completed unless an exception applies, such as for certain nonresident aliens claiming benefits. Primary qualifiers include nonresident aliens required to file U.S. returns due to U.S.-sourced , aliens (determined by ) unable to obtain an SSN, and nonresident alien students, professors, or researchers filing returns or seeking treaty-based exceptions from withholding. Nonresident aliens may also qualify if engaging in U.S. or business or disposing of U.S. interests. status does not affect eligibility, as ITIN issuance is solely for administration and implies no authorization for , Social Security benefits, or changes in standing. Spouses and dependents of U.S. citizens, resident s, or certain nonresident alien visa holders are eligible only if claimed for an allowable tax benefit, such as the , Credit for Other Dependents, or Additional Child Tax Credit. For tax years beginning after December 31, 2017, these individuals cannot obtain or renew an ITIN for zero-income returns or solely for the now-suspended ; a genuine tax benefit or joint filing with a is required. U.S. resident alien dependents may qualify for the Credit for Other Dependents if meeting residency tests. ITINs do not qualify holders for the except in limited cases tied to allowable benefits.
  • Non-eligible scenarios include U.S. citizens, lawful permanent residents eligible for SSNs, or individuals seeking ITINs without a tax filing obligation.
  • Dependents must provide evidence of relationship and identity, with eligibility further restricted if not supporting a tax benefit.

History

Establishment and Early Implementation

The Individual Taxpayer Identification Number (ITIN) was established by the Internal Revenue Service (IRS) in 1996 under Treasury Regulation § 301.6109-1(d)(3), authorizing the issuance of a nine-digit taxpayer identification number to individuals required to provide such a number for federal tax reporting or withholding but ineligible for a Social Security number (SSN). This regulatory measure addressed gaps in tax administration for non-SSN-eligible persons, such as nonresident aliens with U.S.-source income or treaty obligations necessitating filings under the Internal Revenue Code. The regulation appeared in the on May 29, 1996, with the IRS announcing that applications via the newly introduced Form W-7 would be accepted starting July 1, 1996. Form W-7 required applicants to submit supporting documentation verifying identity and foreign status, alongside a federal demonstrating a need for the ITIN, such as for claiming treaty benefits or reporting income. The IRS designed the ITIN format to begin with the number 9, distinguishing it from SSNs (starting with 1-8 or 00-66 for certain blocks) and Employer Identification Numbers, to facilitate processing without implying work authorization or immigration status. Early implementation aligned with the July 1, 1996, target date, as the IRS began processing and issuing ITINs that month to enable timely tax compliance for the 1996 filing season. Initial uptake focused on legitimate tax filers, including foreign investors and dependents, with the program administered through IRS service centers rather than dedicated units, reflecting its origin as a procedural tool rather than a standalone initiative. By facilitating returns without SSN barriers, the ITIN supported revenue collection from taxable activities involving nonresidents, though documentation verification relied primarily on self-attestation and attached returns in the program's nascent phase.

Policy Evolutions and Restrictions

The Individual Taxpayer Identification Number (ITIN) program originated with Treasury regulations finalized in 1996, enabling the IRS to issue nine-digit numbers beginning with 9 to individuals ineligible for Social Security numbers (SSNs) solely for federal tax reporting and withholding compliance, without initial expiration dates or stringent documentation mandates beyond basic identity and foreign status verification. Fraud concerns prompted significant revisions in 2012, when the IRS implemented interim procedures on June 22 requiring all applicants—including renewals—to submit original supporting documents or certified copies from issuing agencies, rather than photocopies, to verify identity and foreign status, while reducing the list of acceptable documents and curtailing exceptions previously allowed for certain filers. These changes, finalized for the 2013 filing season effective January 1, 2013, also introduced a five-year validity period for newly issued ITINs to ensure ongoing legitimate use, marking a shift from indefinite issuance to periodic validation aimed at curbing misuse for non-tax purposes. The Protecting Americans from Tax Hikes (PATH) Act, enacted December 18, 2015, imposed further evolutions by mandating ITIN expiration for non-use on federal tax returns over three consecutive years, with implementation beginning January 1, 2017, alongside accelerated deactivation of ITINs bearing middle digits 78 or 79 (issued 2012–2014) on December 31, 2016, followed by staggered expirations for older series like 88–92 in subsequent years. This policy required affected taxpayers to renew via Form W-7 with updated documentation before claiming refunds or credits, effectively narrowing ITIN utility to active tax participants. Restrictions on ITIN eligibility and benefits have tightened concurrently; since tax years beginning after December 31, 2015, primary taxpayers and spouses using ITINs (rather than SSNs) are ineligible for refundable portions of the , Additional Child Tax Credit, American Opportunity Tax Credit, and , though ITIN-holding dependents may still qualify claimants for allowable benefits if the primary filer has an SSN. For tax years after 2017, spouses and dependents qualify for ITIN issuance only if claimed for a specific tax benefit or required for filing, excluding those solely as household members without tax implications. ITINs remain strictly limited to tax administration, prohibiting use for employment authorization under or systems, and do not confer eligibility for SSN-linked social benefits or work permits.

Application and Administration

Application Requirements and Process

Applicants for an Individual Taxpayer Identification Number (ITIN) must complete Form W-7, Application for IRS Individual Taxpayer Identification Number, and submit it with a completed federal return, such as or Form 1040-NR, unless they qualify for one of the exceptions outlined in the Form W-7 instructions, such as documentation of third-party withholding on or scholarships for dependents. The application must be filed on or before the of the associated to avoid separate processing delays. Supporting documentation is mandatory to establish the applicant's and foreign , consisting of original documents or certified copies from the issuing agency, which must be current and unexpired at the time of submission. A single valid suffices to prove both and foreign without additional documents. In the absence of a , applicants must provide at least two documents: one demonstrating foreign (e.g., foreign , foreign voter's registration card, or Indian and Northern Affairs document) and one verifying with a (e.g., U.S. , foreign , or USCIS Employment Authorization Card). For dependents, proof of U.S. residency—such as a , school record, or letter from a agency—is additionally required unless the dependent qualifies for an exception, like being the or dependent of U.S. stationed overseas. Notarized copies are generally not accepted, except in specific cases involving U.S. military dependents. The application process involves preparing the Form W-7, attaching the tax return and supporting documents, and submitting the package via one of three primary methods. Mailing is directed to the IRS ITIN Operation at P.O. Box 149342, Austin, TX 78714-9342 (or the equivalent private delivery service address at 3651 S. Interregional Highway 35, Austin, TX 78741-0000), where original documents are retained during processing and returned only if a self-addressed certified mailer is included. In-person submission requires an appointment at an IRS Taxpayer Assistance Center (TAC), where staff authenticate documents on-site, photocopy them, and return the originals immediately, followed by mailing the package to the IRS. Alternatively, Certifying Acceptance Agents (CAAs)—IRS-authorized individuals or organizations—can review and certify the authenticity of documents, enabling applicants to submit copies while retaining originals, though CAAs may charge fees for this service. Processing typically requires seven weeks from receipt, but extends to nine to eleven weeks during peak season ( to April 30) or for applications from outside the . Upon approval, the ITIN is issued via letter to the applicant's address, and the is processed separately; rejections occur if documentation is insufficient or if the applicant qualifies for a instead. As of September 2025, revised standards emphasize the use of current Form W-7 and prioritize passports among 13 specified acceptable document types for verifying identity and foreign status.

Renewal, Expiration, and Compliance Burdens

ITINs expire if not included on a U.S. for three consecutive tax years, with expiration occurring on December 31 of the third year of non-use. This rule, implemented under the Protecting Americans from Tax Hikes () Act of 2015, applies prospectively; for instance, ITINs unused on returns for tax years 2021, 2022, and 2023 expired on December 31, 2024. Holders whose ITINs begin with middle digits 70, 71, 72, or 73 (typically issued before 2010) faced earlier phase-out expirations starting in 2016, but current policy emphasizes non-use as the primary trigger. The IRS notifies affected holders via letters, such as CP48R or CP567, urging renewal if a is planned. Renewal requires submitting Form W-7, Application for IRS Individual Taxpayer Identification Number, alongside a tax return or as a standalone application, with processing times averaging seven weeks. Supporting documentation, such as original passports or certified copies from issuing agencies, must verify identity and foreign status, and originals are returned post-processing. No fee applies, but renewals tied to tax filing must occur before using the ITIN on a return to avoid rejection or delays; extensions to October 15 do not extend ITIN validity for filing purposes. Holders not filing returns in the near term need not renew, as expiration only impacts active tax obligations. Compliance burdens stem from stringent documentation mandates and manual processing, which the IRS Taxpayer Advocate Service has identified as a "most serious problem" due to high rejection rates (up to 50% in some periods) from incomplete or mismatched proofs. Applicants often face repeated submissions, with original documents risking loss or delay, particularly for non-residents lacking easy access to certification services. Limited digital options exacerbate issues, as e-filing remains unavailable for most W-7 applications, forcing paper-based handling amid backlogs that can exceed 90 days during peak seasons. These factors discourage timely , potentially leading to unfiled returns and foregone refunds, while straining IRS resources without improving detection efficacy.

Comparison to Other Taxpayer Identification Numbers

Key Differences from Social Security Number

The Individual Taxpayer Identification Number (ITIN) and Social Security Number (SSN) serve as taxpayer identification mechanisms but differ fundamentally in eligibility requirements. An ITIN is issued exclusively to individuals who are not eligible for an SSN yet must comply with federal tax filing obligations, such as nonresident aliens earning U.S.-source income, their nonresident alien spouses or dependents, or certain resident aliens lacking work authorization. In contrast, an SSN is available to U.S. citizens, lawful permanent residents, and non-citizens with explicit work authorization from the Social Security Administration. Regarding purpose and entitlements, the ITIN is restricted to tax administration and processing; it confers no eligibility for Social Security benefits, the , employment authorization, or public assistance programs, nor does it alter an individual's immigration status. An SSN, however, supports broader functions including wage reporting for , qualification for and under the Social Security program, and access to certain federal services tied to lawful presence and contributions. Issuance authorities and processes also diverge: ITINs are assigned by the Internal Revenue Service (IRS) upon submission of Form W-7 with supporting documentation verifying identity and foreign status, often requiring certification by an IRS Acceptance Agent. SSNs are issued by the Social Security Administration, typically integrated with employment verification or benefit claims. Structurally, both are nine-digit numbers formatted as XXX-XX-XXXX, but ITINs are distinguishable by beginning with the digit 9 followed by specific middle-digit ranges (such as 70-88, 90-92, or 94-99) to prevent overlap with SSNs. Additionally, ITINs expire after periods of non-use in tax filings—specifically, those with middle digits 78, 79, or previously 88 became invalid after December 31, 2021, unless renewed—imposing ongoing compliance burdens absent from SSNs, which remain valid indefinitely barring rare revocation. ITINs lack utility as general outside the and cannot be used for employment eligibility verification via , underscoring their narrow scope compared to the SSN's multifaceted role in financial, employment, and governmental interactions.

Distinctions from

The Individual Taxpayer Identification Number (ITIN) and are both nine-digit taxpayer identification numbers issued by the for federal tax reporting purposes, but they differ fundamentally in the entities they identify and their applications. The ITIN is assigned exclusively to individuals, such as certain nonresident aliens, resident aliens, their spouses, and dependents, who have a U.S. tax filing obligation but are ineligible for a . In contrast, the EIN identifies business entities, including corporations, partnerships, sole proprietorships, estates, trusts, and tax-exempt organizations, that must file various business-related tax returns or employ workers. Key distinctions include issuance criteria, usage scope, and structural formatting. ITINs are issued only to individuals without an SSN who demonstrate a need to file U.S. individual returns, such as , and do not confer eligibility for Social Security benefits, work authorization, or other federal programs. EINs, however, are required for entities engaging in activities like hiring employees, filing or tax returns, or operating as a , and they enable withholding and business entity reporting without individual-level restrictions. All ITINs begin with the digit 9 followed by a range such as 70-88, 90-92, or 94-99 to denote issuance batches, whereas EINs use two-digit prefixes from 01 to 99 (excluding certain ranges like 00 or 88 for specific uses) that reflect the type of entity or application method.
AspectITINEIN
Primary IdentifyeeIndividuals (e.g., nonresident aliens without SSN) entities (e.g., employers, corporations, trusts)
Eligibility BasisTax filing requirement without SSN eligibility formation, employment, or entity-specific tax obligations
Common Forms UsedIndividual returns (e.g., , W-7 application) returns (e.g., Form 1120, 941; SS-4 application)
Benefits ConferredNone (tax processing only; no work authorization or SSN benefits)Enables operations like and entity taxation
Expiration/RenewalExpires if unused for three years or upon SSN eligibilityGenerally permanent unless entity dissolves or changes structure
An individual may hold both an ITIN for personal tax matters and an EIN for a separately owned , but the numbers cannot be interchanged, as using an EIN on an individual return or vice versa would result in processing errors or rejection by the IRS. This separation ensures precise tracking of versus entity-level liabilities, preventing conflation of individual and streams.

Usage and Empirical Data

Demographics of ITIN Holders

ITIN holders encompass a diverse group ineligible for Social Security numbers, including nonresident aliens with U.S. tax filing requirements, aliens without work authorization, their spouses, and dependents, often in mixed-status households. As of January 2021, approximately 5.4 million ITINs were active, enabling compliance with federal tax obligations without conferring work authorization or eligibility for most benefits. aliens, along with their spouses and dependents, comprise over 80 percent of ITIN applicants, reflecting heavy use for family members of U.S. citizens or lawful permanent residents. Among those using ITINs on tax returns, roughly 42 percent appear as primary taxpayers, 18 percent as secondary filers (typically spouses), and 40 percent as dependents, underscoring the of ITINs in claiming exemptions or credits for non-eligible family members. In tax year 2022, 3.79 million returns included at least one ITIN, with filing statuses distributed as 41 percent married filing jointly, 35 percent single, 19 percent , and 5 percent married filing separately. These patterns indicate a predominance of family-oriented filings, particularly among low-wage earners supporting dependents. ITIN filers exhibit low-income characteristics, with a median of $31,033 in tax year 2022, and only about 10 percent reporting Schedule C business profits suggestive of . Primary ITIN filers often include undocumented workers in labor-intensive sectors, though the also features non-working foreign students, investors, and retirees with U.S.-sourced . Limited public data disaggregation hinders precise profiling, but historical IRS application records show a concentration among Latin American nationals; in processing year 2012, accounted for 71.9 percent of applications, comprising the bulk of the top origins alongside smaller shares from countries like and . Recent breakdowns by country of remain unavailable, as the IRS prioritizes over detailed demographic releases for this group.

Tax Filing and Revenue Statistics

In tax year (TY) 2022, taxpayers filed 3,791,421 individual returns that included at least one Individual Taxpayer Identification Number (ITIN), accounting for roughly 2.7% of the total individual returns processed by the (IRS). This figure reflects a modest decline from the peak of 4,381,382 returns in TY , amid broader trends influenced by policy changes such as the Protecting Americans from Tax Hikes (PATH) Act of 2015, which imposed expiration and renewal requirements on certain ITINs. Partial data for TY 2023 indicate approximately 3.3 million such returns through September 2024.
Tax YearReturns Filed with at Least One ITIN
20153,766,806
20163,682,228
20173,820,499
20184,099,686
20194,247,447
20204,381,382
20213,821,414
20223,791,421
Source: IRS data as reported by the Taxpayer Advocate Service. ITIN filers contributed substantially to , with reported before credits ranging from $15.9 billion to $19 billion annually across TY 2017–2022. After accounting for allowable credits—typically $2 billion to $4 billion per year, including child credits and earned income credits—the liability fell to $12.4 billion to $17.3 billion in those years. Refunds issued to ITIN filers during this period varied from $3.3 billion in TY 2022 to $6.2 billion in TY 2017, reflecting overwithholding or credit-eligible payments. The median for these filers in TY 2022 was $31,033, underscoring that contributions occur despite relatively modest earnings levels. These statistics derive from IRS processing data and highlight ITINs' role in capturing revenue from non-SSN-eligible taxpayers, though net figures exclude taxes withheld at .

Controversies

Fraud and Identity Misuse

Fraudulent use of ITINs has primarily involved schemes to claim refundable credits, such as the Additional Child Tax Credit (ACTC), by submitting applications with fabricated identities or ineligible dependents, often linked to unauthorized resident aliens. A 2012 Treasury Inspector General for Tax Administration (TIGTA) report identified potentially billions of dollars in improper ACTC claims on returns filed with ITINs, including cases where unauthorized workers received refunds despite ineligibility under residency requirements. For instance, in a sample of 250 flagged ITIN returns from tax year 2009, the IRS issued $46 million in refunds to unauthorized workers, highlighting systemic gaps in pre-refund verification. Patterns of abuse include clustered ITIN applications and returns from single addresses, indicative of organized fraud rings creating fictitious dependents to maximize credits. A 2012 congressional review found 154 mailing addresses used over 1,000 times each for ITIN applications, with 10 addresses alone associated with 53,994 tax returns and $86.4 million in processed fraudulent refunds; similarly, 10 bank accounts received 23,560 refunds totaling over $16 million. Between 1999 and 2003, the IRS identified 12,241 tax returns involving ITINs in refund fraud schemes, resulting in millions of dollars in improper payments, often through lax initial issuance controls that allowed weak documentation like unverified copies of foreign IDs. Identity misuse with ITINs typically entails the fabrication rather than theft of identities, as fraudsters exploit the program's reliance on self-reported foreign documents to establish non-existent taxpayers for claims, bypassing stricter safeguards. Unlike SSN-based , which targets existing records for refund diversion, ITIN often originates in application-stage deception, enabling subsequent filings under false personas without cross-agency data matching until post-issuance audits. This has persisted despite IRS reforms, such as requiring original or certified documents since 2012 and implementing five-year ITIN expirations for non-use, which reduced applications by 27.8% that year but did not eliminate vulnerabilities in seasonal processing backlogs exceeding 1 million returns annually. The absence of a dedicated mechanism for dormant ITINs further allows prolonged misuse by non-compliant filers. The issuance of an Individual Taxpayer Identification Number (ITIN) by the (IRS) occurs independently of an individual's immigration status, serving solely as a tax processing tool for those ineligible for a (SSN), including nonresident aliens and undocumented immigrants. Possession of an ITIN does not authorize employment, confer legal immigration status, or provide any protection against deportation proceedings conducted by agencies such as and (ICE). Under Section 6103 of the , IRS taxpayer information, including ITIN-related data, is generally protected from disclosure to immigration authorities for civil enforcement purposes, a designed to encourage tax compliance without fear of immigration repercussions. This confidentiality has historically insulated ITIN filers from routine use of their tax records in immigration , though exceptions exist for criminal investigations or specific administrative needs unrelated to broad deportation efforts. In April 2025, the IRS and formalized a (MOU) permitting the IRS to share limited taxpayer details—such as names, addresses, and certain tax data—with upon request, primarily targeting individuals with final orders or suspected of immigration violations. The agreement, initiated amid expanded priorities, allows to request information on up to 500,000 individuals annually but requires judicial warrants for broader access and excludes routine sharing for non-enforcement purposes. Legal challenges followed, resulting in a September 2025 federal court order temporarily halting certain disclosures pending resolution of privacy violation claims under Section 6103. This development has heightened concerns among ITIN holders regarding risks, as shared could facilitate location for removal, potentially deterring filings despite ITINs contributing an estimated $23.6 billion in annual federal taxes from undocumented households as of 2019 . Proponents of the MOU argue it aligns administration with by targeting confirmed violators, while critics, including civil rights organizations, contend it undermines the voluntary compliance incentive central to ITIN utility, drawing parallels to past failed attempts at linkage during the administration's first term. Despite these links, remains under Department of Homeland Security jurisdiction, with ITIN compliance neither mitigating nor exacerbating eligibility based on separate statutory criteria.

Criticisms and Reforms

Administrative Inefficiencies and Costs

The administration of the Individual Taxpayer Identification Number (ITIN) program by the Internal Revenue Service (IRS) relies predominantly on manual paper-based processing, which contributes to significant delays, errors, and resource strain. Applications must be submitted via Form W-7 with original or certified supporting documents, lacking any electronic filing option available for other taxpayer identification numbers like Employer Identification Numbers. Processing times average 7 to 11 weeks, extending to 9 to 11 weeks or longer during peak tax season from January 15 to April 30, with common causes including incomplete submissions, document quality issues, and manual reviews without digital verification tools. In fiscal year 2023, the IRS handled 1,032,832 ITIN applications, assigning 1,360,807 ITINs, yet reported 4,043 instances of missing taxpayer documents, highlighting logistical vulnerabilities in handling physical materials. These inefficiencies impose burdens on both taxpayers and the IRS, exacerbating compliance costs and fraud risks. Taxpayers, particularly new applicants, cannot e-file returns, leading to prolonged refund delays and necessitating reliance on Certified Acceptance Agents or preparers, with 90.3% of ITIN filers in using non-credentialed professionals who charge fees up to $2,000, plus indirect costs like travel and lost productivity from document submission requirements. For the IRS, manual processes limit fraud detection capabilities, as evidenced by outdated systems without features like facial recognition or real-time electronic filters, contributing to erroneous ITIN deactivations affecting approximately 70,000 individuals since 2021 and historical vulnerabilities where weak controls permitted improper issuance using fabricated documents. A 2004 investigation demonstrated that ITINs could be obtained with bogus credentials and exploited for fraudulent refunds totaling $22.1 million across 12,241 returns from 1999 to 2003. Policy adjustments, such as the 2012 requirement for original documents, have amplified these issues by increasing rejection rates by 46% and reducing filings by 21.6% initially (27.8% by year-end), straining IRS resources through seasonal bottlenecks and discouraging voluntary compliance without proportionally enhancing revenue collection. The program's design, including restricted year-round processing and inadequate data-sharing with agencies like the Department of Homeland Security, perpetuates administrative overhead, as manual handling diverts personnel from core enforcement activities and elevates security risks from unverified foreign documents. Recommendations from the National Taxpayer Advocate Service include adopting submission and to mitigate these persistent inefficiencies.

Debates on Incentives for Non-Compliance and Policy Alternatives

Critics of the ITIN program contend that its relatively accessible application process and limited integration with create perverse incentives for tax non-compliance, particularly through fraudulent refund claims. For instance, the National Taxpayer Advocate has highlighted how the program's structure incentivizes fraud, such as fabricating dependents to access refundable credits like the Additional , with approximately 72 percent of ITIN applications in processing year 2012 originating from , a associated with elevated unauthorized . This vulnerability persists despite reforms, as ITIN filers disproportionately engage non-credentialed tax preparers—linked to higher error rates and evasion risks—compared to SSN holders. Treasury Inspector General for Tax Administration (TIGTA) audits underscore these concerns, revealing that unauthorized workers have potentially claimed billions in improper tax credits via ITIN-filed returns, with inconsistent IRS processing of flagged fraudulent filings exacerbating underreporting and evasion. Such misuse arises because ITINs enable economic participation—such as wage reporting and refund receipt—without requiring proof of legal work authorization, potentially encouraging off-the-books income concealment or selective compliance where filers report only traceable earnings while evading taxes on unreported cash-based work. Proponents, including immigrant advocacy groups, argue that ITINs enhance overall compliance by bringing previously untaxed income into the system, with undocumented immigrants contributing an estimated $96.7 billion in federal, state, and local taxes in 2022. However, government oversight reports indicate that fraud-related losses, including identity theft and invalid dependent claims, offset much of this revenue gain, fostering debates over whether the program subsidizes non-compliance by decoupling tax obligations from verifiable identity and status. Policy alternatives proposed to mitigate these incentives include stricter verification mechanisms, such as mandatory biometric documentation or real-time cross-checks with Department of Homeland Security databases, to reduce fraudulent issuances while preserving access for legitimate nonresident filers. Legislative efforts, like the 2015 PATH Act's provisions for ITIN expiration after three years of non-use and redesigned numbering to deter , represent incremental reforms aimed at curbing dormant or misused numbers that facilitate evasion. Bipartisan bills, such as one introduced by Rep. and Sen. in 2015, sought to overhaul the application process by requiring enhanced documentation and limiting renewals, though implementation has faced administrative hurdles. More radical alternatives advocate restricting ITIN eligibility to individuals with legal status or work , effectively eliminating it as a tool for undocumented filers and redirecting incentives toward full compliance via Social Security Numbers. This approach, echoed in proposals to condition refundable credits on work-eligible SSNs starting in year 2026, aims to eliminate perceived subsidies for partial compliance while potentially increasing revenue by deterring fraudulent claims. Critics of retention argue that without such linkage to enforcement—despite IRS policies against routine with authorities—the program perpetuates a parallel prone to , whereas abolition could compel underground economies into formal channels or reduce unauthorized presence altogether. Empirical assessments from TIGTA suggest that enhanced fraud detection, rather than expansion, would better align incentives with genuine compliance.

Broader Impacts

Effects on Tax System Integrity

The Individual Taxpayer Identification Number (ITIN) program, established in , has been criticized for introducing vulnerabilities that compromise the integrity of the U.S. tax system, particularly through inadequate identity verification processes. (GAO) investigators demonstrated in that ITINs could be obtained using fabricated documents submitted by mail, without in-person verification required for most applicants, enabling subsequent misuse such as opening bank accounts or even . By the end of , over 7 million ITINs had been issued, with limited third-party validation exacerbating risks of improper issuance to ineligible individuals, including unauthorized workers. These weaknesses have facilitated tax fraud, including and bogus refund claims. Between 1999 and 2003, the IRS identified 12,241 fraudulent returns using ITINs that sought $22.1 million in refunds, with approximately $18 million prevented through interventions. High-profile schemes, such as one in involving 9,664 false returns, highlight how ITINs serve as entry points for organized fraud, distinct from more rigorously verified Social Security Numbers. Moreover, analyses by the IRS and Treasury Inspector General for Tax Administration (TIGTA) indicate that most ITIN holders reporting wage income are engaged in unauthorized employment, contributing to discrepancies like the Social Security Administration's earnings suspense file, which recorded about $936 million in unreconciled wages under ITIN-like identifiers from 1996 to 2000. Ongoing administrative inefficiencies further erode system integrity by hindering timely fraud detection and enforcement. The program's reliance on manual, paper-based processing—averaging over 1 million applications annually from 2018 to 2023—results in 7- to 11-week delays, lost original documents (e.g., 4,043 missing in 2023), and erroneous ITIN deactivations affecting tens of thousands of accounts since 2021. In tax year 2022, the IRS issued 21,999 math error notices invalidating ITINs, impacting 31,999 dependents and disallowing $6 million in credits, often due to inconsistent handling rather than confirmed . The IRS's reluctance to digitize applications, citing fraud risks from sophisticated forgeries like AI-generated documents, perpetuates bottlenecks that burden legitimate filers and impair broader compliance monitoring. While ITINs enable tax participation from approximately 3.8 million returns in tax year 2022—yielding $17.3 billion in reported taxes paid—the program's design elevates overall fraud exposure without commensurate safeguards, diverting resources from core enforcement and allowing non-compliant actors to exploit tax benefits intended for verifiable taxpayers. This dynamic, as noted in TIGTA assessments, poses challenges to efficient tax administration, particularly for returns filed by resident aliens lacking work authorization.

Economic and Fiscal Consequences

The ITIN program enables the collection of federal taxes from individuals ineligible for Social Security numbers, including nonresident aliens and certain resident aliens, thereby incorporating income from otherwise informal economic activity into the taxable base. In tax year , approximately 3.79 million tax returns included at least one ITIN, with total liability before credits amounting to $18.2 billion and total taxes paid reaching $17.3 billion. After accounting for $3.7 billion in credits and a net refund outlay of $3.3 billion, the program yielded a net federal revenue contribution of roughly $14 billion from these filers. This revenue stems primarily from wage withholding and taxes, reflecting labor participation in sectors such as , , and services where ITIN use formalizes earnings that might otherwise evade taxation. Economically, ITIN-facilitated compliance expands the effective tax base by capturing contributions from immigrant workers whose output supports GDP growth—estimated at billions in annual labor value—without granting access to major entitlements like Security benefits or the for primary ITIN taxpayers. However, ITIN holders remain ineligible for refundable portions of credits such as the unless dependents possess SSNs, limiting fiscal outflows while sustaining revenue inflows. Broader analyses indicate that undocumented immigrants, many of whom rely on ITINs, paid $59.4 billion in federal taxes in 2022, bolstering short-term deficits by increasing revenues more than associated in projections. Fiscal consequences include heightened administrative burdens on the IRS due to manual document verification and paper processing, which delay refunds and strain resources amid rising application volumes—nearly 900,000 ITINs issued in calendar year 2023 alongside over 250,000 rejections. While precise costs are not itemized in recent reports, these inefficiencies contribute to costs for other activities, potentially undermining overall system productivity. Critics argue the program indirectly sustains a parallel workforce that accesses state and local services—such as education and emergency healthcare—imposing uncompensated fiscal loads estimated in broader immigration studies at tens of billions annually, though ITIN-specific net impacts remain positive at the federal revenue level due to benefit restrictions.

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