ITINs on W-9s and 1099s: format, expiry, revocation and what still matches

Which 9xx numbers are ITINs

The manual states the structure in one sentence: "The ITIN will be in the format of an SSN and begin with the number '9'. The fourth and fifth numbers will range from: 50-65, 70-88, 90-92, 94-99." Two groups are carved out: "'89' and '93' are NOT used as fourth and fifth numbers for ITINs but are reserved for other programs" (IRM 3.21.263.2(9)-(10), Aug. 28, 2025). The 93 group is the Adoption Taxpayer Identification Number, ATIN (IRM 3.21.263.9.3.5(4), May 12, 2025). The rest of the 9xx space belongs to the IRS's own placeholders. An Internal Revenue Service Number, IRSN, also begins with 9, and its fourth and fifth digits are a campus code (table below; IRM 3.21.263.5.5, Jan. 1, 2015). The manual is blunt: "An IRSN is not a valid TIN" (IRM 3.21.263.6.4.1 Reminder, Aug. 28, 2025); it "is used only as an internal identifying number or until the taxpayer is assigned an SSN or ITIN" (IRM 3.21.263.5.5(3)).

If a payee reads a number off an IRS notice and its middle digits fall in the IRSN ranges, it is not a TIN for your purposes; the TIN format checker applies these ranges. Two more lines settle common W-9 arguments. A payee holding a Social Security card marked Not Valid for Work should give the SSN: "SSN is the valid TIN for tax filing or reporting purposes" (IRM 3.21.263.5.1(3) Caution, Jan. 1, 2024). And since December 2003 ITINs have been issued by letter, the CP 565, not by card (IRM 3.21.263.5.9(1) Note, Jan. 30, 2025).

The ITIN lifecycle

The assignment date on a new ITIN is the W-7 received date (the paragraph that follows is redacted), and on a renewal the assignment date shown "remains the original date" (IRM 3.21.263.2.2(4)-(5), Nov. 12, 2021). A renewed ITIN is the same number; nothing on the W-9 changes.

Non-use expiry: only a 1040 stops the clock

The PATH Act created two expiry rules. The first is non-use: "All ITINs, no matter when they were issued or renewed, that are not used on at least one U.S. federal tax return in the last three tax years will expire on December 31 of the third consecutive year." The second retired every pre-2013 ITIN on a schedule by middle digits that finished on Jan. 1, 2021 (IRM 3.21.263.2.1(1)-(4), Jan. 1, 2023). What "used on a return" means is the part payers get wrong. The manual's definition: "the ITIN must be a 'valid' ITIN and belong to the primary, secondary, dependent, or child and dependent care qualifying person listed on the tax return" (IRM 3.21.263.2.1(2) Note). A 1099-INT or 1042-S filed under the ITIN is not a tax return in this sense. A nonresident landlord or foreign account holder who receives only information returns will see the ITIN expire every three years no matter how faithfully you report.

The payee is usually the last to know. "Taxpayers are NOT issued a CP 48 notice for ITINs expired for non-use. Notification will be made using other communication channels (e.g., irs.gov, outreach, etc.)" (IRM 3.21.263.8.2(4) Reminder, Jan. 1, 2023). The CP 48 and Letter 5821 were mailed only from 2016 through 2020 for the middle-digit expirations (IRM 3.21.263.5.9(1)). The manual also tells phone assistors who needs to act: taxpayers "ONLY need to renew their expired ITIN ... if they ARE filing a federal income tax return using the ITIN ... If taxpayer is NOT filing a federal income tax return using the expired ITIN(s), they do NOT need to take any action" (IRM 3.21.263.8.2(4)). Renewal requires a Form W-7 with a federal return attached "unless they are eligible for one of the five exceptions" (IRM 3.21.263.2.1(7); 3.21.263.5.2(2), Jan. 30, 2025), and it can be filed "at any time" (IRM 3.21.263.8.2(9)).

An expired ITIN is not a revoked ITIN

This distinction answers the question payers actually ask: does an expired ITIN break TIN matching? The manual never discusses Form 1099 or 1042-S filings against an inactive ITIN, and says nothing about TIN Matching results, CP2100 notices or backup withholding; those are outside its scope. What it does say is enough to reason from. DM-1 is the file that decides validity: an ITIN is "invalid" when "the ITIN and name on DM-1 do not match" (IRM 3.21.263.2.1(2) Note). An expired ITIN keeps its DM-1 entry and its name control; the status flag changes, the record stays. Only revocation removes it: revoked ITINs "are removed from DM-1. DM-1 will not contain any data for the ITIN such as name control or DOB ... Revoked ITINs are not recycled or reissued" (IRM 3.21.263.2.1(6) Note).

The revoke reasons are a short list (IRM 3.21.263.9.3.8, Mar. 2, 2016): R 15, an SSN has been assigned ("ITIN is no longer valid"); R 14, multiple ITINs; R 11, deceased; R 07, entitled to an SSN; and R 26, assigned in error, also used for fraud determined by Criminal Investigation. A CP 567 is issued on revocation (IRM 3.21.263.8.5(4), Jan. 31, 2019). The practical rule for a payer: a name and ITIN that matched last year and fails this year is far more likely a revocation, usually R 15 after an SSN was issued, than an expiry. Ask the payee whether they have an SSN before you ask them to renew.

When the payee gets an SSN

A payee who obtains an SSN "do[es] NOT need to renew their ITIN" (IRM 3.21.263.8.2(11)). Accounts Management initiates a merge of the two accounts, and the ITIN is later revoked under R 15 (IRM 3.21.263.8.3(2), Aug. 28, 2025; 3.21.263.8.5 and 8.6). The timing has a wrinkle: merges may first post to "the invalid side of IMF" and move to the valid side at "the quarterly DM-1 update" (IRM 3.21.263.6.7(2) Exception, May 12, 2025). For a vendor file, that means a payee who reports a new SSN in February may not have the SSN and name paired on DM-1 until the next quarterly refresh, while the old ITIN stops matching once revoked. Re-solicit a W-9 as soon as the payee reports the SSN and file under it; if a TIN match on the new number returns a name mismatch in the first quarter, keep the W-9 and retry after the quarterly update rather than treating the payee as unresponsive.

CP 565, CP 566, CP 567 and CP 574

The manual's notice list (IRM 3.21.263.5.9, Jan. 30, 2025) is short. CP 565 A (and its Spanish version, A-SP) is the systemic "Assigned, Active / Inactive, or Renewed Notice" and "Includes an Active or Inactive indicator." CP 565 B is a reissued copy. CP 566 is the suspense notice: the application is "not processable ... additional information must be submitted," and the applicant now has 120 days to respond (raised from 45 in 2025), with a systemic reject at 140 days. CP 567 is the rejection: "a new Form W-7 must be submitted." It is also the notice issued on revocation. CP 574 is the hard reject issued when "the federal tax return did not reflect a filing requirement," being replaced by Letter 6628. Notices generate three business days after the application is created (IRM 3.21.263.8.3(3)), and when a Certifying Acceptance Agent filed it the notice goes to the applicant and the agent, except that "If the CAA is a financial institution, the notice will only be issued to the CAA" (IRM 3.21.263.5.9(3)); a bank customer may never have seen their own CP 565.

One more limit. W-7 data is return information; callers must pass an eight-element authentication (Exhibit 3.21.263-3), and unauthenticated callers get only "general ITIN information" (IRM 3.21.263.8.1(4), Aug. 28, 2025). A payer cannot call the ITIN unit to confirm a payee's ITIN or an application's status; the manual has no payer-facing line and no procedure for payer contact. TIN matching is your only check.

Processing times

Phone assistors quote seven weeks, or nine to eleven weeks for applications received between Jan. 15 and Apr. 30 or from abroad, and have the applicant resubmit if there is no record after that (IRM 3.21.263.3.3(3), Jan. 4, 2024; 3.21.263.8.3(2), Aug. 28, 2025). A payee who filed a W-7 in March on the strength of your letter should not be expected to produce an ITIN before June, and a suspended application adds up to 120 days. The manual sets no separate standard for an exception-only application without a return, other than the gaming and FIRPTA turnarounds. The backup withholding guide covers what to do while you wait.

Your letter is the payee's ticket to an ITIN

A payee with no U.S. return to file (a foreign account holder, a nonresident partner, a foreign landlord, a pension recipient) applies under one of five exceptions, and the document the IRS examines comes from the withholding agent (IRM 3.21.263.5.2(4), Jan. 30, 2025; 3.21.263.6.3.5.2, Aug. 28, 2025). Exception 1 covers third-party withholding on passive income. For a bank account the manual requires "An original signed letter from the bank on its official letterhead, displaying the applicant's name and stating that they have opened a[n] ... account which is subject to IRS information reporting and/or federal tax withholding on the interest generated during the current tax year." For other distributions: "An original document or signed letter from the withholding agent that is on official letterhead, shows the individuals name and requirement for ITIN in order to make distributions during the current tax year which are subject to federal tax withholding and/or reporting requirements" (IRM 3.21.263.6.3.5.2(9)). Rental income letters need not mention withholding. A partnership interest is proven with the partnership agreement showing the applicant's name and signature and the partnership's name and EIN, which "may be written on the partnership agreement, printed on the CP 575 series EIN confirmation notice, or printed on Letter 147C" (IRM 3.21.263.6.3.4.3(3), Aug. 28, 2025).

"Letterhead" is read loosely: it "may or may not contain a name, address and a logo" (IRM 3.21.263.6.3.5.2(9)). What fails is the payee's own printout: "If the only documentation is a self-generated income statement from a web site (for example, Amazon) filled in by the taxpayer, consider the document invalid"; a contract or "a letter with a postmarked envelope addressed from the withholding agent" rescues it (IRM 3.21.263.6.3.4.3(3) Note). The rejects that follow a bad packet are R 19, no exception documentation; R 21, exception documentation invalid; and R 23, effectively connected income without a return (IRM 3.21.263.5.8.2, June 20, 2024). "A request for an EIN (Form SS-4) is not a valid exception and does not make the applicant eligible for an ITIN" (IRM 3.21.263.6.3.5.2(8) Note). The withholding agent ITIN exception letter template carries the required elements.

Treaty payees: Form 8233 and W-8BEN before the ITIN exists

Exception 2 is where the order of operations bites. A foreign individual claiming a treaty rate on wages, honoraria or scholarship income needs the treaty country and article on the W-7 and, for 2(a), a "Copy of completed withholding agent's portion of Form 8233"; for 2(b), a "Copy of W-8 BEN submitted to the withholding agent" with the award letter, passport with visa and an SSA rejection or school official letter (IRM 3.21.263.6.3.5.2(10); 3.21.263.6.3.4.3(3)). The IRS expects to see your completed part of the Form 8233 in the W-7 packet, so you complete it before the payee has a TIN, not after. Examiners may perfect a W-7 from "Treaty country and article indicated on some Form 8233" (IRM 3.21.263.6.3.1(7), June 27, 2025), but a treaty claim without a country and article is rejected under R 16 (IRM 3.21.263.5.8.2). Gambling winnings, Exception 2(d), have the fastest lane: a casino acting as a Certifying Acceptance Agent faxes the W-7, identification copies and a Form W-8BEN showing the treaty country and article, and Austin processes "within 24 hours of receipt," faxing back the ITIN or "Rejected due to XXXXXXX" (IRM 3.21.263.6.9.4, June 20, 2024). Without a casino agent the visitor files Form 1040-NR at year-end with the W-7 and a "copy of Form 1042-S displaying the amount of tax withheld" (IRM 3.21.263.6.3.5.2(10)). The foreign vendor guide covers the W-8 side.

FIRPTA buyers, briefly

Exception 4 is the buyer or withholding agent on a U.S. real property sale by a foreign person. The W-7 travels with Form 8288, 8288-A or 8288-B and the sales contract or Closing Disclosure; here, uniquely, the Form 8288 series is accepted as exception evidence (IRM 3.21.263.6.3.5.2(12)). Austin edits the ITIN onto the 8288 series "within 10 days of receipt" and returns copies to the Ogden FIRPTA unit by fax; a rejected W-7 is marked "ITIN REJECT" on the 8288, and an 8288 that arrived with a remittance carries an IRSN later merged into the ITIN (IRM 3.21.263.6.9.1, Mar. 16, 2023). A seller who quotes a 9xx number from that stage may be quoting the IRSN.

CP 565 acceptance checklist for AP

The manual never tells a payer how to treat a CP 565 offered with a W-9, but it gives the facts a checklist needs.

• Indicator. Confirm the notice shows Active. The CP 565 A carries "an Active or Inactive indicator," and a new one prints on any name or address change without a renewal (IRM 3.21.263.5.9; 3.21.263.2.3(2) Reminder). A CP 565 B is a reissued copy, not a renewal.
• Name. The W-9 name should be the CP 565 name; assistors are told to "Advise the caller to use the name as it appears on the ITIN assignment notice to avoid delays" (IRM 3.21.263.2.3(2)). A name change not yet in the system needs a marriage certificate, divorce decree or court order with the W-7 (IRM 3.21.263.8.2(5) Note).
• Name control. The IRS name control is the "first four characters of the last name," and on a dual surname it "should match the last name, or one of the dual last names" (IRM 3.21.263.9.3.3.1, Dec. 8, 2017). The manual's own caution is a two-word surname stored as "Lunar Purple" with a name control of LUNA (IRM 3.21.263.2.3(2) Caution). If TIN matching fails on a multi-word surname, try the first word before you send a B-Notice. See IRS name control.
• Match anyway, and retain. A CP 565 proves the number was assigned to that name on the date shown, not that the pair is on DM-1 today; run the TIN match and keep the CP 565 copy with the W-9.

Questions people ask