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TYM Business Consulting is now an IRS-authorized Certifying Acceptance Agent (CAA) - a designation that changes how ITIN applicants verify their identity and submit their applications to the IRS. For non-residents and foreign nationals who need a U.S. Individual Taxpayer Identification Number, this means original passports no longer need to be mailed to the IRS. This article explains what a Certifying Acceptance Agent is, how it differs from a standard Acceptance Agent, who needs an ITIN and why, and what the application process looks like when working with a CAA.
An Individual Taxpayer Identification Number (ITIN) is a nine-digit tax processing number issued by the IRS to individuals who have a U.S. tax filing or reporting obligation but are not eligible for a Social Security Number. For Canadians with U.S. rental property, U.S.-source income, or interests in U.S. business entities, the ITIN is the identification number required for U.S. tax compliance. Without it, a U.S. tax return cannot be filed, treaty benefits cannot be claimed, and withholding taxes on U.S.-source income cannot be reduced.
The usual method for applying for an ITIN involves mailing Form W-7 along with original identity documents, usually a passport, to the IRS in Austin, Texas. For applicants in Canada, that means weeks without a passport, the risk of documents being lost in transit, and a processing timeline that can stretch to seven to ten weeks or more during peak tax season. A Certifying Acceptance Agent eliminates the mailing requirement entirely. As an authorized CAA, TYM Business Consulting verifies identity documents in person at our Toronto or Miami offices, certifies copies, and submits the application directly to the IRS without the applicant ever mailing their passport.
Certifying Acceptance Agent vs. Acceptance Agent: What the Difference Means in Practice
The IRS Acceptance Agent Program includes two levels of authorization.
A standard Acceptance Agent (AA) is authorized to assist applicants in preparing and submitting Form W-7 (Application for IRS Individual Taxpayer Identification Number). However, an AA cannot verify or authenticate identity documents. As a result, applicants must still mail their original identification documents to the IRS or present them in person at an IRS Taxpayer Assistance Center.
A Certifying Acceptance Agent (CAA) holds a higher level of authorization from the IRS. A CAA is permitted to review original identity documents, certify copies as accurate, and submit the ITIN application on the applicant’s behalf. The application is accompanied by a Certificate of Accuracy (Form W-7 COA). In these cases, the IRS accepts the CAA’s certification rather than requiring original documents, significantly simplifying the application process for the taxpayer. To obtain CAA status, a firm must complete IRS-mandated training, including forensic document examination, which covers assessing the authenticity of passports and other identity documents. CAAs are subject to both correspondence and physical compliance reviews by IRS Stakeholder Liaison staff. The authorization is not automatic or permanent - it must be maintained through ongoing compliance with IRS program requirements.
For applicants outside the United States - particularly Canadian residents who cannot easily visit a U.S. Taxpayer Assistance Center - the practical difference between AA and CAA is significant. With a CAA, the entire ITIN application process can be completed in Canada, without mailing original documents across the border.
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Who Needs an ITIN: Common Situations for Non-Resident and Cross-Border Clients
Non-resident owners of U.S. rental property
Non-resident individuals who own residential or commercial property in the United States and receive rental income are subject to U.S. federal tax on that income. Without an ITIN, the default withholding rate on gross rental income paid to a non-resident landlord is 30 percent of gross receipts, with no deduction for expenses. Filing Form 1040-NR with a valid ITIN allows the owner to elect net income taxation - paying tax only on net profit after deducting mortgage interest, property taxes, depreciation, and other eligible expenses. For properties with material costs, the difference between gross and net taxation can be substantial. This situation applies broadly to non-residents from Canada, the U.K., Mexico, and any country whose nationals own U.S. real estate.
Sale of U.S. real property (FIRPTA)
Under the Foreign Investment in Real Property Tax Act (FIRPTA), the buyer of U.S. real property from a non-resident seller is required to withhold 15 percent of the gross sale price and remit it to the IRS. The seller can apply for a withholding certificate to reduce this amount if the actual tax liability is lower, but that application requires an ITIN. Without one, the seller cannot file the return required to claim a refund of any excess withholding, which is often the largest portion of the 15 percent withheld. FIRPTA applies to all non-resident sellers regardless of country of residence.
U.S.-source income subject to withholding
Non-resident individuals who receive U.S.-source income - dividends, royalties, interest, or payments for services performed in the United States - may be subject to withholding at up to 30 percent. Many U.S. tax treaties reduce withholding rates on specific categories of income, but claiming treaty benefits requires filing a U.S. return with a valid ITIN. Without one, the reduced treaty rate cannot be applied and excess withholding cannot be recovered. This applies to non-residents from any country that has a tax treaty with the United States.
Foreign nationals with U.S. business interests
Foreign nationals who hold interests in U.S. LLCs or partnerships have U.S. tax filing obligations at the individual level, because pass-through income from these entities is reportable on a U.S. return regardless of whether distributions are made. This requires an ITIN. It applies to any non-resident investor or business owner holding a membership interest in a U.S. LLC or a partnership interest in a U.S. partnership, regardless of country of residence.
Spouses and dependents on a U.S. tax return
A non-resident spouse or dependent of a U.S. citizen or resident who does not have a Social Security Number needs an ITIN to be claimed on a U.S. tax return. This applies whether the family member is being claimed as a dependent or is filing jointly with a U.S. citizen or resident spouse. Without the ITIN, the return cannot include the family member, which affects filing status and may reduce the refundable credits available to the household.
ITIN renewal
ITINs expire if they have not been used on a U.S. federal tax return for three consecutive years. ITINs not included on a return for tax years 2022, 2023, or 2024 expired on December 31, 2025. Additionally, ITINs with certain middle-digit ranges issued before 2013 have expired under prior IRS notices regardless of use. Filing with an expired ITIN causes the return to be processed without it, which can delay refunds and prevent certain credits from being claimed. Renewal follows the same Form W-7 process as a new application, and a CAA can complete the renewal without the applicant mailing original documents.
How the ITIN Application Process Works with a Certifying Acceptance Agent
The ITIN application process through a CAA differs from the standard process in one essential respect: the applicant’s original identity documents are verified in person by the CAA rather than being sent to the IRS. The CAA examines the originals using the forensic document training required for CAA authorization, certifies copies as accurate, and attaches a Certificate of Accuracy (Form W-7 COA) to the completed Form W-7 application. The package is then submitted directly to the IRS. The applicant keeps their passport.
Both the IRS standard process and the CAA process require an in-person or video interview with the applicant, which the IRS mandates for all ITIN applications. At TYM Business Consulting, this interview is conducted at our Toronto or Miami offices. The applicant presents their original identity documents - typically a passport, which is the only single document that independently satisfies both the identity and foreign status requirements - and these are verified and certified during the appointment.
A passport that does not contain a date of entry is not accepted by the IRS for ITIN purposes. If the applicant’s passport lacks a date of entry, a combination of at least two other documents must be presented instead, with at least one including a photograph. The CAA reviews the documents against IRS requirements before the application is submitted, which reduces the risk of rejection due to documentation issues - one of the most common causes of application delays.
In most cases, Form W-7 must be submitted with a completed U.S. tax return. Specific exceptions apply for treaty benefit claims, FIRPTA withholding applications, and certain third-party withholding situations. Processing time for a complete and accurately prepared application is typically seven to ten weeks during peak tax season (January through April). Outside of that period, the IRS processing timeline may vary.
A Canadian resident who had purchased a condominium in Florida was subject to 30 percent gross withholding on rental income for two years. An ITIN application was completed through TYM’s CAA process: the applicant presented their passport at our Toronto office and kept it throughout. Form 1040-NR was filed to elect net income taxation, significantly reducing the effective tax rate on the rental income. A refund claim was submitted for excess withholding from the prior year.
What TYM’s CAA Authorization Means for Clients
TYM Business Consulting operates from Toronto and Miami and has provided cross-border tax services for clients in Canada and the United States across individual and corporate engagements. The CAA authorization adds a specific capability: the ability to manage the complete ITIN application process in-house, from document verification through submission, without requiring clients to mail original identity documents internationally.
For clients who already work with TYM on U.S. non-resident returns, FIRPTA withholding, cross-border structure planning, or U.S. LLC and partnership compliance, the CAA service means the ITIN application is handled as part of the same engagement. For new clients whose first step is obtaining an ITIN - a Canadian purchasing U.S. real estate, a non-resident with newly acquired U.S. income, a Canadian owner of a U.S. business entity - the application is the starting point for a coordinated process that includes the applicable U.S. return, the treaty position, and any ongoing filing obligations.
The CAA authorization follows the opening of TYM’s Miami office and reflects our continued investment in the compliance infrastructure required for U.S.-Canada cross-border tax work. Becoming a Certifying Acceptance Agent required completing the IRS application process, the mandatory forensic document training, and agreeing to the IRS Acceptance Agent program requirements, including regular compliance reviews. It is an authorization that reflects a level of IRS oversight and accountability that standard tax preparers do not carry.
Next Step
If you need an ITIN for U.S. rental income, a property sale, treaty benefit claims, U.S. LLC or partnership filing obligations, or any other U.S. reporting requirement, TYM Business Consulting can manage the complete application process as an IRS-authorized Certifying Acceptance Agent. Identity documents are verified at our Toronto or Miami offices - your original passport stays with you throughout.
TYM Business Consulting provides CPA-led ITIN application services, U.S. non-resident tax return preparation (Form 1040-NR), FIRPTA withholding planning, and cross-border tax compliance for clients in Canada and the United States. Our CAA authorization is part of the compliance infrastructure we have built to support U.S.-Canada cross-border tax work at both the individual and corporate level.
To begin your ITIN application or to discuss your U.S. tax filing obligations, request an ITIN consultation from TYM Business Consulting.
Frequently Asked Questions
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