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How to Renew an Expired ITIN: Step-by-Step Guide for Non-U.S. Residents

If your Individual Taxpayer Identification Number hasn't been used on a U.S. tax return in the last three years, or it was issued before 2013, it's likely expired — and filing with it anyway can freeze your refund or trigger a rejection notice months later. This guide walks through exactly how to renew an expired ITIN as a non-U.S. resident: which documents you need, how to fill out Form W-7 correctly, and what to expect once you submit.

Why Your ITIN Expired (and Why It Matters for Non-Residents)

ITINs aren't permanent by design. The IRS built an expiration schedule into the program back in 2016 as part of the PATH Act, specifically to force periodic revalidation of taxpayer records. Two triggers cause an ITIN to expire:

• Non-use: If you haven't included your ITIN on a federal tax return for three consecutive tax years, it expires automatically on December 31 of the third year.
• Middle-digit rollouts: The IRS previously deactivated ITINs in batches based on the middle two digits of the number (for example, ITINs with middle digits 88, or 90–99 assigned before 2013). Most of these scheduled deactivations have already occurred, but if you were issued an ITIN in the early rollout years and haven't renewed since, yours may already be inactive.

For non-residents, this matters more than it might seem. If you're an Amazon seller filing an annual 1040-NR, a landlord reporting rental income, or a foreign investor claiming a treaty-reduced withholding rate, an expired ITIN doesn't just cause a paperwork hiccup — it can stall your entire return in IRS processing, delay a refund by months, and in FIRPTA withholding cases, hold up tens of thousands of dollars tied to a property sale. We've covered the mechanics of this in more detail in Does an ITIN Expire? What Non-U.S. Residents Need to Know.

How to Check If Your ITIN Needs Renewal

Before assembling documents, confirm you actually need to renew. Three quick checks:

1. Middle digits: If your ITIN's format is 9XX-XX-XXXX and the middle two digits fall in the ranges the IRS has already flagged for expiration (70–88, or 90–99 issued before 2013), it's expired unless you've already renewed it.
2. Filing history: Pull your last three years of U.S. tax filings. If your ITIN doesn't appear on any return filed in that window, it expired as of December 31 of the third unused year.
3. IRS notice: If the IRS has already tried to process a return with your ITIN, you may have received a CP48 notice stating the number needs renewal before your return can be processed.

If none of these apply, your ITIN is likely still active, and you don't need to file Form W-7 again — just use it as normal on your next return.

Documents You'll Need to Renew an Expired ITIN

Renewal applications require nearly the same documentation as a first-time ITIN request. The IRS accepts 13 types of supporting identification documents, but a passport is the only one that works as a stand-alone document — every other option (national ID card, birth certificate, foreign driver's license, etc.) has to be paired with a second document to prove both identity and foreign status.

Beyond ID documents, you'll typically need:

• A completed Form W-7 marked for renewal (more on this below)
• No new tax return in most cases — renewals filed for an existing, previously-used ITIN generally don't require an attached return, unlike first-time applications
• Proof of U.S.-source income or a treaty claim, if applicable to your situation (e.g., a 1099, K-1, or closing statement from a property sale)

If you're unsure which combination of documents applies to your country and circumstance, our breakdown in What Documents You Need for an ITIN Application: Complete Guide for Non-U.S. Residents goes through country-specific edge cases in more depth.

Step-by-Step: Completing Form W-7 for Renewal

1. Check the "Renew an Existing ITIN" box at the top of Form W-7. This is the single most commonly missed step — applicants often complete the form as if it's a first-time request, which slows processing because the IRS has to manually reclassify the submission.
2. Enter your existing ITIN in the space provided. Don't leave this blank or write "N/A" — the whole point of a renewal is matching your new documents to your existing number.
3. Select the correct reason for applying. For renewals, this is usually the same box you checked originally (e.g., "Nonresident alien filing a U.S. tax return" or the applicable box tied to your income type).
4. Fill in your full legal name exactly as it appears on your identification document. Mismatches between the name on your ID and the name on file with the IRS are a top cause of rejection.
5. Provide your foreign address, even if you also have a U.S. mailing address — the IRS wants your permanent residence, not a P.O. box or agent address.
6. Sign and date the form. Unsigned forms are an automatic bounce-back.
7. Attach your identification documents — originals, notarized copies through the appropriate channel, or certified copies from the issuing agency.

If you want the full field-by-field walkthrough for the base form (not just the renewal-specific boxes), see Form W-7 Line By Line: How To Complete Your ITIN Application As A Non-U.S. Resident.

Common Mistakes That Delay ITIN Renewals for Non-U.S. Applicants

• Mailing an expired or soon-to-expire passport. The IRS requires the passport to be valid at the time of submission — an expired passport gets the whole package rejected.
• Submitting uncertified photocopies. Unless mailed to the IRS as originals, documents need certification directly from the issuing agency (e.g., the passport office) or authentication through an IRS-authorized Certifying Acceptance Agent.
• Inconsistent names across documents. A married name on a bank statement but a maiden name on a passport, for example, creates a mismatch the IRS won't resolve on its own.
• Skipping the renewal checkbox. As mentioned above, this alone can add weeks because the application enters the wrong processing queue.
• Assuming dependents renew the same way as primary applicants. Dependents often need additional proof of U.S. residency or school records depending on age and country.

We go deeper into the full universe of rejection triggers — not just renewal-specific ones — in Why ITIN Applications Get Rejected and How to Prevent Each Rejection Before You Submit.

How Long Renewal Takes and What to Expect After Submission

According to IRS guidance, standard ITIN processing — including renewals — takes about 7 weeks from the time a complete application is received, extending to 9–11 weeks during peak filing season (typically late January through April) or if you're submitting from overseas. Incomplete applications or those requiring follow-up documentation can take considerably longer.

Once approved, the IRS mails a CP565 notice confirming the renewed ITIN. If you submitted original documents like a passport, those are returned separately — sometimes after the confirmation letter itself, which understandably causes anxiety for applicants who need their passport back for travel or banking. For a closer look at what specifically extends or shortens these timelines, see What Affects ITIN Processing Time and How to Avoid the Delays That Add Weeks.

What Happens If You File Taxes with an Expired ITIN

Filing a return with an expired ITIN doesn't cause outright rejection at the moment of submission — the IRS will still accept the return into its system. The problem shows up downstream: the return is processed as filed, but any refund is held, and exemptions or credits claimed under that ITIN may be disallowed until the number is renewed. If you're expecting a refund tied to over-withheld income — including FIRPTA withholding on a property sale — that refund simply sits in limbo until you submit a valid renewal.

This is a particularly costly trap for non-resident property sellers. FIRPTA withholding is often set at 15% of the gross sales price, well above the seller's actual tax liability, and the refund process already depends on a valid ITIN being on file. An expired number means the refund claim can't move forward at all, regardless of how strong the underlying case is. If FIRPTA is part of your situation, it's worth reading Understanding FIRPTA: How Foreign Property Sellers Can Avoid Delays and Refund Losses alongside your renewal planning, since timing the two processes together avoids a second round of IRS correspondence.

How Nolly Helps Non-Residents Prepare a Clean ITIN Renewal Package

Nolly is an independent document preparation service — we are not affiliated with the IRS, and ITINs are issued solely by the IRS itself, not by us. What we do is handle the part that trips up most non-resident applicants: assembling a renewal package that matches IRS documentation standards on the first attempt, so your Form W-7 doesn't bounce back for a mismatched name, an uncertified copy, or a missing checkbox.

For non-resident LLC owners, e-commerce sellers, and international founders juggling ITIN renewals alongside EIN applications or FIRPTA refund claims, we coordinate the full documentation set so nothing gets submitted piecemeal. If you're not sure whether you need an ITIN, an EIN, or both before your renewal, ITIN vs EIN: What's the Difference and Which One Do You Need? is a useful starting point before you begin the paperwork.

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