Update on IRS Processing of Certified True Copies of Canadian Passports

In late 2023 we began to hear rumblings of a small number of ITIN applications being rejected for not meeting the IRS criteria for document verification. At the time, the data points were from outside sources rather than our customers, and it seemed to be few and far between. We know that the IRS can be quite inconsistent in the way they assess applications, so we didn’t see a need to make any drastic changes. 

Now that a few months have passed, we have more confirming evidence that there will be additional complications for the ITIN application process for Canadian passport holders. While there are still some unknowns, in this post I’ll go over everything we know and what we recommend going forward, for the time being, for Canadians applying for an ITIN. 

Change: Government of Canada No Longer Embosses Dry Seals onto Certified True Copies

In Fall of 2023, the Government of Canada updated its website with a small change to the way certified true copies of passport documents were processed. They would no longer emboss a dry seal onto the passport document photo.

This was a relatively minor change, as you can see in the example image above. Nonetheless, knowing how picky the IRS can be with distinguishing things like certification vs. notarization, it’s not entirely surprising that this could lead to issues with acceptance. 

Also note that it’s not fully established that all Service Canada locations, Canadian embassies, and consulates have discontinued doing the embossed dry seal. There were a few rumblings of people being able to specifically request Service Canada to do the embossing.

Issue: Datapoints of IRS Not Accepting Certified Copies without Embossed Seal

At present, it seems more and more the case that the IRS will not accept the Certified True Copies of Canadian passports when submitted without the seal. When this happens, you will receive a CP566 notice, a 4-page letter from the IRS stating that: 

1. They are unable to accept the submitted documents as they don’t meet the IRS criteria.
2. New documentation must be submitted (valid passport or other documentation) by the provided date.
3. A form must be completed (pages 3 and 4 of the notice) and submitted with the new documentation.

Typically, by the time you receive the notice, the time you have left to resubmit the document is rather tight. However, this isn’t of great concern as you can simply resubmit the entire W7 and 1040 NR again with the new documentation. 

Given this new complication in the ITIN application process, for Canadian passport holders only, we no longer recommend Certified True Copies as the preferred document for identity verification with the IRS.  

We present our recommendations with an explanation for each in the next section.

What Frugal Flyer Recommends Going Forward

Option 1: Send in Original Documentation

We previously cautioned against sending in an original passport, as it wasn’t worth parting with one’s passport for weeks to months, and the small risk of it being lost in the mail (whether due to one’s own error or the IRS’). Particularly when you could just have copies made and send those.

However, with the Certified True Copy situation, sending in an original passport is the most surefire and low-effort method to get an ITIN application approved and processed. 

Furthermore, you can expedite the return of your documents by including a prepaid Express Mail or courier envelope with your initial application package. I recently did this for a family member and we received the passport back in approximately 4 weeks. Do note that the cost is typically in excess of US$50-75 whether with FedEx, UPS, or DHL. 

The IRS states that the submitted documents will be returned within 60 days. Otherwise, you can call the telephone help number:  800-829-1040 from within the US (toll-free), or 267-941-1000 from outside the US (not toll-free).

Note: Alternative to Passport, you may try submitting a Driver’s License and Birth Certificate. These are both listed as acceptable forms of documentation in the revised application standards for ITINs. However, in full transparency I have no datapoints of these being either accepted or declined.

Option 2: Visit an IRS Taxpayer Assistance Center

If you are traveling through the US, or can easily make a trip there, visiting an IRS Taxpayer Assistance Center (TAC) is another reliable way to have your application processed. You can view a list of centers, their locations, and contact information here.

The main drawback of this method is that you need to go in person, but on the flip side, you won’t need to part with your passport at all. 

One other possible frustration is the fact that some TACs can be difficult to reach over the phone to set up an appointment in advance. Customers report difficulty getting through or having calls blocked when originating from Canada/Canadian numbers. We recommend trying different times of the day or using a US VoIP number to make the call. 

Option 3: Try Your Luck With Government of Canada Certified Passport Copies

Based on what we’ve been seeing, I believe the IRS does have a directive to not accept Certified True Copies of passports lacking any seal or emboss. However, it also seems that the execution of this directive is inconsistently applied. While we’ve now seen a significant number of submitted applications get rejected since the Government of Canada change, many applicants still seem to be “slipping through the cracks”, so to speak. 

Even as recently as a few weeks ago, one customer mentioned that on a call with the IRS regarding their CP566 notice, the agent recommended to re-submit an image from the Government of Canada showing the statement that official Certified True Copies would no longer have an embossed seal.

I also had a customer who was successful in submitting a certified true copy, a copy of the Government of Canada’s website explaining that Canada doesn’t emboss anymore, and their birth certificate.

All this is to say that, depending on your situation and comfort with options #1 and #2 above, it may not be unreasonable to attempt applying with a Certified True Copy, with the understanding that rejection is probable and you will likely need to explore other options after the “hail mary” attempt.

Conclusion

As with many things in the world of miles and points, the ITIN application process is dynamic and evolving. While the identity verification component of the application has become a bit less straightforward for the time being, there is no telling whether this is the new status quo, or whether the IRS or the Government of Canada will change their processes again in the future.

Similarly, and to again draw comparisons to miles and points, it often pays to hastily jump on opportunities when they’re available, lest they inevitably disappear. The process for applying for ITIN has continued to get more restrictive, and there is no telling what will happen to it in the future. Missing out on the massive opportunities provided by the US credit card market would be regrettable, which is why we recommend getting started with our guide to US credit cards for any miles and points enthusiasts who have yet to do so.