Pub. 7 2018 Issue 3

17 f a l l | 2018 • Full legal name, • Date of birth for individuals, • Physical address, and • Identification number. CIP and CDD ID Numbers Per the BSA requirements, an identification number for a US person (US citizens and resident aliens) is a tax- payer identification number (TIN) and an identification number for a non-US person is one or more of the following: a TIN; a passport number and country of issuance; an alien identification card number; or a number and country of is- suance of any other unexpired gov- ernment-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. There are five types of taxpayer identification numbers: • Social Security Number (SSN) • Employer Identification Num - ber (EIN) • Individual Taxpayer Identifica - tion Number (ITIN) • Taxpayer Identification Number for Pending US Adoptions (ATIN) • Preparer Taxpayer Identification Number (PTIN) Compliance professionals must un- derstand the rules impacting identifica - tion numbers to ensure compliant IRS information reporting and BSA/AML programs. This has become an even more important aspect since imple- mentation of the Beneficial Ownership Rules. Unlike the CIP rules requiring a one-time identification and verifica - tion of the customer upon establishing the first customer relationship, the new Beneficial Ownership Rule requires obtaining and verifying CIP-like information each time a new account is established. Individual Taxpayer ID Numbers An Individual Taxpayer Identifica - tion Number (ITIN) is a US tax pro- cessing number issued by the Internal Revenue Service (IRS). Non-US citizen individuals (foreign nationals) that do not have an SSN and are not eligible to obtain an SSN but have a requirement to furnish a federal tax identification number or file a federal income tax return, must apply for an ITIN. The IRS issues ITINs to foreign nationals and other non-US citizens who have federal tax reporting or filing require - ments and do not qualify for SSNs. For example, non-resident alien individual’s ineligible for an SSN but required to file a US tax return only to claim a refund of tax under the provisions of a US tax treaty need an ITIN. Other examples of individuals who need ITINs include, but are not limited to: • A nonresident alien required to file a US tax return, • A US resident alien (based on days present in the United States) filing a US tax return, • A dependent or spouse of a US citizen/resident alien, or • A dependent or spouse of a nonresident alien visa holder. An ITIN is a nine-digit number that always begins with the number 9 and Continued on page 18...