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Issue 63760

Identity Protection Personal Identification Numbers (IP PINs) for Overseas Taxpayers

Issue Statement:

Educate and Improve the access of online PIN services to international taxpayers.

Goal Statement:

Educate and Improve the access of online PIN services to international taxpayers.

RECOMMENDATION 2866

RECOMMENDATION TEXT:

Increase awareness and educate international taxpayers on how to apply for an online account. US citizens living abroad are not aware that they can obtain an IP PIN to secure their tax returns. Some international taxpayers file a return when there is no requirement to file to prevent fraud (Right to a Quality Service).

IRS Action: Adopted

W&I C&L will help ensure prominent placement on IRS.gov, include reminders in appropriate external communications channels, including traditional and social media, partner outreach, etc.

RECOMMENDATION 2867

RECOMMENDATION TEXT:

Align form 15227 and the IRS website to show that there is no longer an income limit to request an IP PIN. Excerpt from Form 15227 (3) Your adjusted gross income on your last filed return is below; For Individuals $73,000 or For Married Filing Joint $146,00 FAQ Q21: Q21: If I cannot validate my identity through the Get an IP PIN tool, how else can I participate in the IP PIN Program? A21: There are two alternatives to receive an IP PIN: If your adjusted gross income is below $73,000 for Individuals or $146,000 for Married Filing Joint, you can file Form 15227, Application for an Identity Protection Personal Identification NumberPDF. To file Form 15227, you must have: o A valid Social Security number or Individual Taxpayer Identification Number, An adjusted gross income of $73,000 for Individuals or $146,000 for Married Filing Joint or less, Access to a telephone. If you are unable to verify your identity online or with the Form 15227 process or are ineligible to file Form 15227, you may schedule a visit at a Taxpayer Assistance Center to request an IP PIN. Form 15227 and FAQ Q21 say there is an income limit. However, there has been an update but the forms and other website references for an IP PIN do not reflect the removal of the income limits.

IRS Action: Not adopted

The income limits were never planned to be removed. In fact, the limits were increased for 2024 to $79K for individuals and $158K for Married Filing Joint. The income limits are based on the limits set for Free File which encompasses around 70% of the tax filing population.

RECOMMENDATION 2868

RECOMMENDATION TEXT:

Increase awareness that a taxpayer can retrieve their IP PIN via a toll-free number (800-908-4490) via blogs, articles, Facebook, training videos etc. The right to privacy, confidentiality, and quality service.

IRS Action: Adopted

W&I C&L will promote IPPIN information in appropriate communications channels.

RECOMMENDATION 2870

RECOMMENDATION TEXT:

Expand translation of Form 15227 into other languages than English and Spanish, Box F: Expand language outside of English and Spanish (same for this box). As foreign nationals move to the US, we must ensure that we have forms, instructions, and documents in multiple languages. Forms in multiple languages ensure that the taxpayer understands and complies with IRS tax laws.

IRS Action: Not adopted

Form 15227, Application for an Identity Protection. Personal Identification Number (IP PIN), only requires the individual to fill-out basic information such as name, address, TIN, phone number, and whether the applicant is a dependent. Such information is commonly required for many forms. In most cases, processing Form 15227 requires us to call the submitter, at which time, the individual can request a translator in their language of choice. Given that the form requires basic information from the individual, and the individual can request a translator during processing of the form, we do not agree with the recommendation.

RECOMMENDATION 2871

RECOMMENDATION TEXT:

Ensure that the taxpayers are aware of the calling hours and the respective time zones on form 15227 Box e. It is unclear whether a call will be made in the taxpayer time zone or the IRS representative or assistor time zone. It should also be clarified if the caller is an international taxpayer (right to be informed). Box e – Please provide telephone number where person in ‘Box a’ can be reached during business hours. If dependent child or dependent relative, provide phone number of parent or legal guardian. We will contact person in ‘Box a’ to verify and authenticate their identity. If when we call you, you may choose to verify the caller is an IRS employee. In this case, please call the IRS toll-free at 800-908-4490 for specialized assistance, Monday – Friday, 7 a.m. – 7 p.m. your local time (Alaska & Hawaii follow Pacific Time).

IRS Action: Adopted

We agree to clarify the language relating to the time zone and international taxpayers. Below is our suggested wording change. e – Telephone number with area code at which person in ‘Box a’ may be contacted, Monday – Friday, 7 a.m. – 7 p.m. their local time (Alaska & Hawaii follow Pacific Time). International applicants please choose a time between 6 a.m. – 11 p.m. EST. Instructions for Submitting this Form. Box e – Please provide telephone number where person in ‘Box a’ can be reached during business hours. If dependent child or dependent relative, provide phone number of parent or legal guardian. We will contact person in ‘Box a’ to verify and authenticate their identity. If we call you, you may choose to verify the caller is an IRS employee. In this case, please call the IRS toll-free at 800-908-4490 for specialized assistance, Monday – Friday, 7 a.m. – 7 p.m. their local time (Alaska & Hawaii follow Pacific Time). International users can call us at 1-267-941-1000 (not toll free) between 6 a.m. – 11 p.m. EST.

RECOMMENDATION 2872

RECOMMENDATION TEXT:

Expand using the upload document tool for form 15227. To streamline the completion of tax forms and mailing forms back and forth, there should be improved technology to upload forms (Right to a quality service).

IRS Action:

In June 2023, we included Form 15227 in the list of forms to be incorporated into the Digital and Mobile Adaptive Forms (DMAF). Form 15227 is not scheduled for release 1 in April 2024, but will be considered for a subsequent release in 2025.

RECOMMENDATION 2873

RECOMMENDATION TEXT:

Ability to upload Form 15227 PDF with other tax return documents. If a person is applying for an IP PIN, there should be the ability to upload this form with the tax return/amended return (Right to a quality service).

IRS Action: Not adopted

We do not agree to this suggestion. When forms are attached to a tax return, they are often overlooked and do not reach the intended inventory workload. It would be much more efficient to fax or mail the form as directed. In the future, we plan to have the DMAF functionality for F15227 as a third option.

RECOMMENDATION 2874

RECOMMENDATION TEXT:

Enable the capability to eFax form 15227. The current process allows for mailing and faxing via a scanner/printer. To ensure that the IRS keeps up with technology, there should be an eFax option for all forms (right for a quality service).

IRS Action:

The fax number on Form 15227, 855-807-5720, is an eFax number.