The Internal Revenue Service (“IRS”) has announced changes to its program for Individual Taxpayer Identification Numbers (“ITINs”). These changes will require some taxpayers to renew their ITINs, starting in October 2016.

An ITIN is a number issued to individuals who, among other things, may not be eligible for Social Security numbers (“SSNs”). This could include FNs who are not eligible for SSNs because they are not authorized to work. Under the IRS’s new rule, ITINs will no longer be valid if they have not been used on a tax return for the past three years. In addition, ITINs issued prior to 2013 that have been used on a tax return within the past three years still must be renewed before they can be used on another return. Individuals interested in complying with this new rule should check the IRS website,