CP 574 / Letter 6628: ITIN application hard reject: no filing requirement on the attached return

What CP 574 / Letter 6628 is

The hard-reject notice issued when a Form W-7 arrived with a federal return that "did not reflect a filing requirement"; the manual records that CP 574 is being replaced by Letter 6628 (IRM 3.21.263.5.9, Jan. 30, 2025; Material Changes (119)). The matching status code is HR 1, a return that "cannot calculate tax liability" (IRM 3.21.263.5.7, Jan. 1, 2024). It is the notice a payee receives when they attached a return to qualify for an ITIN instead of using one of the five exceptions.

The deadline

No deadline stated. The applicant must reapply.

What to do

A payee who receives only information returns from you and has no U.S. return to file should apply under an exception rather than with a return; Exception 1 covers interest, dividends, pensions, annuities, royalties, rents and partnership distributions and is documented by your letter on letterhead (IRM 3.21.263.6.3.5.2(9), Aug. 28, 2025). Give the payee that letter and expect seven to eleven weeks after the new W-7 is filed.

Why an attached return gets an application rejected

Form W-7 can be filed with a federal income tax return, and for most applicants that is the route: the return needs a TIN, the W-7 supplies one, and the return is processed once the ITIN is assigned. The IRS checks that the attached return actually requires a number, meaning that it shows a filing requirement and computes a tax liability or a refund. A return that shows no income, or only income that is not taxable to the filer, or that was attached simply to have something to attach, does not qualify, and the application is hard-rejected on that ground. CP 574, now being replaced by Letter 6628, is that rejection. The applicant must reapply, and the usual reason the first attempt failed is that the person did not need to file a return at all; their U.S. income consists of interest, dividends, rents, royalties or other payments that a payer reports and withholds on, and the correct route was always an exception application.

Pointing the payee to the exception route

A payee of yours who receives a CP 574 or Letter 6628 almost certainly qualifies for Exception 1, which covers individuals with U.S. income subject to third-party reporting or withholding and no return to file. The documentation for it is your letter: on letterhead, naming the payee as on the W-7, stating that they hold an account or contract with you that will produce payments subject to IRS information reporting or withholding this year, naming the income type, signed and dated. The withholding agent ITIN exception letter is written to the IRS's requirements. The payee files a new W-7 with the letter and their identity documents, without a return, and should expect seven to eleven weeks. In the meantime the payee has no TIN, so backup withholding or chapter 3 withholding continues on reportable payments, and the 1099 or 1042-S for the year is filed with the TIN blank and a note in your solicitation log that the ITIN application is pending. The ITIN guide covers the five exceptions and the letter in detail.

Questions about CP 574 / Letter 6628

Have a different notice? The IRS notice decoder lists all 77 in the order they tend to arrive.