When an ITIN Application Doesn’t Require a Tax Return

Most applicants must attach a U.S. federal tax return (Form 1040 or 1040-NR) when applying for an ITIN using Form W-7. But there are special exceptions where the IRS allows an ITIN application without filing a tax return.

If you qualify, you can save time and avoid unnecessary paperwork. Let’s look at the key exceptions.

1. Claiming Tax Treaty Benefits

If you are a nonresident alien eligible for a reduced tax rate or exemption under a U.S. tax treaty, you may apply for an ITIN without a tax return.

Examples include:

• Students or researchers receiving U.S. scholarships

• Investors earning U.S. dividends or royalties covered by treaty provisions

👉 In these cases, you submit Form W-7, along with a letter or statement from your withholding agent (such as a university or financial institution).

2. Mortgage Interest Reporting

Foreign individuals who own U.S. property may need an ITIN so their mortgage interest can be reported to the IRS.

You do not need to file a tax return upfront. Instead, you provide Form W-7 with a copy of your mortgage documents.

3. Third-Party Information Reporting

Sometimes banks, brokers, or other U.S. institutions require an ITIN for reporting interest or income.

For example:

• Opening a U.S. bank account that earns interest

• Receiving distributions from a U.S. partnership

👉 Here, the institution typically issues a letter confirming the need for an ITIN, which you attach instead of a tax return.

4. Dispositions of U.S. Real Property (FIRPTA)

If you are a nonresident alien selling U.S. real estate, the IRS requires an ITIN to process FIRPTA withholding and refunds.

• You do not attach a tax return when applying.

• Instead, you include closing statements, sales contracts, or withholding certificates as proof.

5. Other Limited Cases

The IRS lists a few additional exceptions, such as:

• Certain foreign individuals claiming tax-exempt income

• Dependents of U.S. citizens or residents in specific circumstances

Each case requires supporting documentation instead of a tax return.

Why Exceptions Matter

• Saves time if you don’t have a filing obligation yet

• Prevents unnecessary tax return preparation

• Ensures compliance without IRS rejection

But remember: if you don’t meet an exception, you must attach a tax return. Submitting Form W-7 alone without eligibility will likely result in rejection.

Get Expert Help with ITIN Exceptions

Determining whether you qualify for an ITIN exception can be tricky. That’s where House of Bookkeepers — IRS Certified Acceptance Agent (CAA) — can help.

We:

• Review your case to check if you qualify for an exception

• Prepare and verify all supporting documents

• Submit your ITIN application securely without mailing your passport to the U.S.

📍 Apply today at houseofbookkeepers.com and get your ITIN letter with confidence.