Adoption Taxpayer Identification Number (ATIN) Notes for EA Exam

What is an ATIN?

A 9-digit temporary number issued by the IRS for a child in a domestic adoption when adoptive parents cannot obtain the child's Social Security Number (SSN).

• Purpose: Used on federal tax returns to identify the child while the adoption is pending.
• Limitations:
  • Cannot be used for Earned Income Tax Credit (EITC).
  • Temporary until an SSN is obtained post-adoption.

Who Needs an ATIN?

Adoptive parents in the process of adopting a child who:

• Can claim the child as a dependent or for the Child and Dependent Care Credit.
• Cannot obtain the child's existing or new SSN.

Eligibility for an ATIN

Parents must meet all of the following:

• Child is legally placed in the home for adoption by an authorized agency.
• Adoption is domestic or a foreign adoption with a Permanent Resident Alien Card or Certificate of Citizenship.
• Parents cannot obtain the child’s SSN after reasonable attempts (e.g., from birth parents or agency).
• Parents cannot obtain an SSN from the SSA (e.g., adoption not final).
• Parents are eligible to claim the child as a dependent.

Why is an ATIN Needed?

Tax law requires a valid taxpayer identification number for dependents listed on a tax return. An ATIN is used when an SSN is unavailable to claim:

• Dependency exemption.
• Child and Dependent Care Credit (if eligible).

How to Apply for an ATIN

• Form: Use Form W-7A, Application for Taxpayer Identification Number for Pending Adoptions.
• Documentation: Attach placement documentation, such as:
  • Placement agreement from an adoption agency.
  • Hospital document authorizing release for adoption.
  • Court order or document approving placement.
  • Affidavit from an attorney or government official per state adoption laws.
• Requirements: Documentation must include adoptive parents’ names, child’s name, agency name, placement date, and signatures of parents and agency official.
• Submission: Mail to Internal Revenue Service, Austin Service Center, ATIN Unit, P.O. Box 934, Austin, TX 78767, or drop off at an IRS walk-in office.
• Note: Send copies, not original documents, as they will not be returned.

Validity and Deactivation

• Duration: Valid for two years or until adoption is finalized and an SSN is obtained.
• Deactivation:
  • Automatic after two years if no SSN is reported.
  • Deactivated when IRS is notified of the child’s SSN via Form 15101.
• Extension: If adoption is not finalized, request an extension using Form 15100 (included in 18-month reminder notice).

When to Apply

• Apply as soon as eligibility conditions are met.
• Submit at least 8 weeks before the tax return due date (typically April 15).

Processing Time

• 4–8 weeks after IRS receives a completed Form W-7A.

Tax Benefits and Limitations

• Allowed:
  • Dependency exemption (per Publication 501).
  • Child and Dependent Care Credit (per Publication 503).
• Not Allowed: Earned Income Tax Credit (EITC) requires an SSN.

Key Forms and Publications

• Form W-7A: Application for ATIN.
• Form 15100: ATIN Extension Request or to report address changes.
• Form 15101: Report child’s SSN or address changes.
• Publications:
  • 501: Exemptions, Standard Deductions, and Filing Information.
  • 503: Child and Dependent Care Expenses.

Post-Adoption

• Obtain an SSN for the child once adoption is finalized.
• Notify IRS of the SSN using Form 15101 to deactivate the ATIN.

Exam Tips

• Focus Areas:
  • Eligibility requirements for ATIN vs. ITIN vs. SSN.
  • Tax benefits (dependency exemption, Child and Dependent Care Credit; EITC not allowed).
  • Application process (Form W-7A, placement documentation).
  • Validity, deactivation, and extension procedures.
• Common Questions:
  • Who qualifies for an ATIN?
  • Which tax benefits can be claimed with an ATIN?
  • How to apply and handle expiration?
• Key Notes:
  • ATIN is for domestic adoptions or foreign adoptions with specific documentation.