Immigrant tax return processing – ITIN program updates Archives

IRS Initiates Reporting of Forensic Document Training

Just as there is a formal credit reporting process for IRS approved continuing education providers, so will there be for the IRS approved Forensic Document Training course providers. The IRS has emailed approved CAA Forensic Document Training providers to initiate the certificate verification process.

The ITIN Policy Section tax analyst has requested an initial catch-up list of all Forensic Document Training course completions with respective completion dates and names from January 1, 2025 through August 30th, 2025. Ongoing, credit reporting for our forensic document training, Fraudulent document recognition, will be done monthly.

Gentle reminder that the IRS has set a time limit on the validity of your forensic document training certificate at 120 days from the date on your certificate. As always, digital copies of the certificate are not accepted for your CAA application. The IRS wants you to submit a scanned copy of your physical forensic document training certificate.

If you are interested in applying to become a certifying acceptance agent, check out this blog post for our tips on navigating the CAA application process.

Tina HarveyAugust 5, 2025Immigrant tax return processing – ITIN program updatesforensic document training, fraudulent document recognition

Avoiding Mistakes When Applying to Become an Acceptance Agent in 2025

Know where to apply

Since the moratorium ended, Acceptance Agent applications have moved to IRS e-services for citizen/legal resident alien applicants in the U.S. Foreign nationals will still complete form 13551, but now instead of mailing the application, they will upload the completed application to participate here (https://apps.irs.gov/app/digital-mailroom/caa/).

It’s important to note that the e-services helpdesk will not assist you with your certifying acceptance agent application no matter how you are applying.

Navigating E-services

IRS E-services has primarily been used for e-file applications and other e-file related designations and identification numbers. It was only recently (Jan 2024) that Form 13551 was essentially digitized into the online acceptance agent application that we now know. (As mentioned in the previous section, foreign nationals will not apply via e-services.) In order to get into e-services, the applicant must go through id.me if they have not already done this. This is the company that the IRS uses to validate the identity of users. After setting up the account with id.me, you will log into e-services with your id.me login. After successfully logging into e-services, you can start a new application. In the drop down box you will select acceptance agent application. From here, the application process is fairly straightforward up to submission. If you encounter errors saying that your information doesn’t match IRS records, you will need to confirm all the data entered. If you continue to get this error, the next course of action would be e-mailing the ITIN office for assistance (ITINprogramoffice@irs.gov). It can take days to weeks to get a reply back, but they will follow up with you eventually. Do not send duplicate emails. The ITIN office is a very small office, and they are responsible for assisting all active Acceptance Agents and applicants.

Uploading Your Documentation

After completing and submitting your online acceptance agent application in your e-services account, you will then need to go upload your documentation on another IRS webpage (https://apps.irs.gov/app/digital-mailroom/caa/ ). You will need to upload proof of any designations that you hold that may prevent the need to complete fingerprints. For example, if you are an ERO, you can include your EFIN letter. You can upload your EA license or PTIN certificate to validate your tax preparer credentials. Upload your forensic document training certificate that you got upon completing your required forensic document training course. The forensic document training course is an online course that teaches the student about fraudulent document recognition. This certificate is good for 120 days from the issue date. The IRS advises the applicant to start the return when they have the certificate in their possession.

Replying to IRS Responses

Paper notices will still be sent to applicants. If you get a response from the IRS regarding your certifying acceptance agent application, it is important to check the statement date and respond immediately. Usually the response timeframe begins from the date on the letter, however, the letter may not arrive to you until later. For example, you receive a notice from the IRS regarding your previous year's tax return. They noticed that you have your tax business and daycare business on the same schedule C (real situation we assisted). They want you to fix it and reply to them within 30 days from the date on the letter. The letter is dated July 10th, but today is the 24th, you have two weeks left to correct the issue and reply in a timely manner before the IRS automatically issues a rejection on your application to participate. Other reasons you might get a response could be payroll issues, business entity type issues, and other personal tax or immigration reasons.

Signing Your Agreement

This is maybe the trickiest part of the acceptance agent application process. Once you have submitted your application and all of your required documentation in the appropriate places, the IRS will begin to process your application. There is a specific area that you will go to in order to manage your application. When you log into e-services, it will be the middle entrance option. You will be able to see when your application is under review. You will only have the option to "sign" when they have completed this step. There is a drop down box where you can select the documents to view, your agreement and addendum. You will have "sign" in that same drop down box. Click on "Sign" and then it will disappear. Once you no longer see "Sign" in the drop down box, you have probably successfully signed the agreement. There is no download or confirmation. We advise checking on your application after this step to ensure processing gets completed. For a CAA renewal, we have seen this take a few weeks to get reinstated. For an initial application, that timeframe could be longer based on other application particulars.

Tina HarveyJuly 23, 2025How to File Tax Returns for Undocumented Aliens – ITINs, Immigrant tax return processing – ITIN program updates, ITIN Application process – General Overviewacceptance agent application mistakes, caa application process, irs acceptance agent application

Common Challenges in ITIN Applications and How to Overcome Them

Applying for an Individual Tax Identification Number (ITIN) can a simple process but it can also get complicated. In this blog, we will explore some of the common challenges the ITIN application process.

Documents

The most common obstacle in applying for an ITIN is getting the appropriate documentation for the taxpayer or dependent. The documentation must be valid. Nothing expired can be used. The IRS has a short list of specific documents that can be used to establish the applicant’s identity and foreign status. You can overcome this challenge by requesting from all applicants a valid passport with at least 6 months before expiration. This is a stand-alone document for ITIN application purposes which means, for taxpayers, that it is the only form of identification that they will need in order to apply for their ITIN. Dependents with passports will need additional documents based on age. If the applicants do not have passports, valid government issued photo IDs and original birth certificates will be the next documents to request.

Tax Purpose

Not everyone is eligible for an ITIN. ITINs are issued based on need and “tax purpose” to individuals with U.S. tax-filing requirements who do not qualify for a social security number. From the purview of the IRS, the sole purpose of the issued ITINs is to facilitate required tax filings. While there are exceptions to the tax filing requirement, just wanting an ITIN for any other reason may not be enough to qualify for an ITIN, and this can present as a challenge when a prospective client calls requesting one. You can overcome this challenge by familiarizing yourself with the exceptions to the tax filing requirement.

Additionally, simply because an individual was issued an ITIN in the past that does not mean that they are necessarily eligible for renewal if it expires. Tax purpose can change from year to year. For example, year 1, an ITIN applicant may be the dependent of a taxpayer living in the USA and meeting the substantial presence test. The “tax purpose” for the dependent is the tax credit and possible change of filing status that the dependent brings to the tax return. Year 2, the dependent is no longer a dependent. They continue to reside in the USA and meet the SPT. They are self-employed and listed as the primary taxpayer on their own tax return. In year 2, meeting their tax filing obligation is their tax purpose. Let us change the scenario a bit and say that in year 2, instead of remaining in the USA, the dependent returned to their country of origin. They did not meet the SPT for the year, they have no US filing requirements for that year, and they are not able to be claimed as a dependent. They have no tax purpose for that year and they do not file a tax return. After a period of non-use, the IRS will automatically deactivate the unused ITIN. Later on, if the individual, once again, has a US tax filing requirement or tax purpose, they would need to apply for their ITIN to be renewed. An ITIN that is used every year is not at risk of deactivation.

Tax Work

Over the last decade, two large legislative packages passed into law (PATH & TCJA) which included verbiage that changed the tax law as it relates to ITINs. Before these tax law changes, the tax treatment of ITIN holders was (almost) identical to that of a citizen (minus the eligibility for EITC). Due to the legislative changes from the Protecting Americans from Tax Hikes Act, there are no retroactive credit claims for ITIN holders. This means that in order for an ITIN-holding taxpayer to get their maximum refund available, they need to file on time (including extensions) each year. This seemingly small change had a huge impact ITIN tax filing because it prevented taxpayers with newly-issued SSNs from amending their prior-year tax returns to claim credits for which they were previously ineligible, such as the Earned Income Tax Credit (EITC).

ITIN holders are not eligible for the Earned Income Credit, even if the taxpayer's listed dependent children are US citizens. However, ITIN-holding taxpayers were eligible for the Child Tax Credit and the Additional Child Tax Credit until the first Trump administration passed the Tax Cuts & Jobs Act. The TCJA removed personal exemptions which was an inherent tax purpose for ITIN-applying dependents. It prevented ITIN-holding dependents from being eligible for the Child Tax Credit and the Additional Child Tax Credit while creating a less-beneficial credit for dependents who did not qualify for the CTC or ACTC called the Other Dependent Credit.

Because of these legislative changes, timing is important to ensure that the tax return is correct and accurate in requesting credits for dependents on which their respective tax purposes depend. The real challenge here is attempting to prevent an ITIN rejection for lack of tax purpose due to timeliness, which you can overcome by staying on top of current tax laws and by filing the taxes on time.

For example, let us say that a small family needs to file taxes and apply for ITINs. They are low-income, self-employed ITIN applicants with an ITIN-applicant dependent. If the only tax on the return is self-employment tax, the credit for other dependents is unused and irrelevant. Unless the dependent has another tax impact, like a filing-status change, they may have lost their tax purpose. On a tax return that has multiple ITIN applications, it is not uncommon for some applications to be approved and others rejected. After ITIN processing, the tax return gets processed and automatically adjusted to omit any rejected applicants.

These are just a few of the challenge areas in the tax world when you work with ITIN applications, but by requesting up-to-date identification documents, staying on top of tax law changes, and familiarizing yourself with the ITIN exceptions, you will be more effective and able to reduce redundant tax work which will save you (and your client) time and money.

Tina HarveyJune 2, 2025Immigrant tax return processing – ITIN program updatesITIN application challenges

Do I need Forensic Document Training for the IRS?

The Internal Revenue Service (IRS) entrusts Certifying Acceptance Agents (CAAs) with a critical role: verifying the identities of foreign individuals applying for Individual Taxpayer Identification Numbers (ITINs). This responsibility necessitates a high level of expertise in detecting fraudulent documents. To ensure CAAs possess this skillset, the IRS mandates the completion of quality forensic document training. If you are interested in becoming a CAA, you will need to complete an approved Forensic Document Training program and provide a copy of your certificate to the IRS during the application process.

Reasons for the inclusion of Forensic Document Training in the application to participate

Combating Identity Theft and Fraud: ITINs are vital for foreign taxpayers to file tax returns and claim tax benefits. Fraudulent applications using stolen identities can lead to significant tax revenue loss for the government. Forensic document training equips CAAs with the tools to identify inconsistencies, alterations, and other red flags in passports, driver's licenses, birth certificates, and other identification documents.
Maintaining National Security: ITINs can be misused for money laundering and other illicit activities. By ensuring the legitimacy of applicants, CAAs contribute to national security efforts by preventing individuals with malicious intentions from obtaining ITINs.
Protecting Vulnerable Populations: Foreign nationals seeking ITINs may be unfamiliar with the application process and vulnerable to exploitation. CAAs with proper forensic document training can safeguard these individuals by preventing them from unknowingly submitting fraudulent documents.
Ensuring Data Accuracy: Accurate identification verification is crucial for maintaining the integrity of the ITIN program. Forensic document training helps CAAs avoid errors that could lead to incorrect data being entered into the IRS system.
Building Public Trust: A robust ITIN program with stringent identity verification measures fosters trust among both foreign taxpayers and the American public. Quality forensic document training for CAAs demonstrates the IRS's commitment to a secure and reliable system.

What Constitutes Quality Forensic Document Training?

The IRS doesn't endorse specific training providers, but the program should encompass the following:

In-depth analysis of various identification documents used globally, including passports, visas, birth certificates, and driver's licenses.
Techniques for detecting alterations, forgeries, and counterfeiting using specialized equipment and visual inspection methods.
Understanding security features incorporated into legitimate documents, such as watermarks, holograms, and microprinting.
Staying current with evolving trends in document fraud and the latest tactics used by criminals.

By requiring CAAs to undergo rigorous forensic document training, the IRS safeguards the integrity of the ITIN program, protects national security, and fosters trust within the tax system. This training empowers CAAs to act as a vital line of defense against identity theft, fraud, and other security threats.

Use code CAA20 to take $20 off the cost of your Forensic Document Training course.

Tina HarveyJune 28, 2024July 18, 2024Immigrant tax return processing – ITIN program updatesFDR course for CAA, forensic document training