U.S. or Foreign TINs — 2026 Publ 515 (PDF)

As the withholding agent, in many cases you must request that the payee provide you with its U.S. TIN. You must in such a case include the payee’s TIN on forms, statements, and other tax documents. The payee’s TIN may be any of the following.

An individual may have a social security number (SSN). If the individual does not have and is eligible for an SSN, go to SSA.gov/ssnumber/ for more information. The SSA will tell the individual if they are eligible to get an SSN.
An individual may have an IRS individual taxpayer identification number (ITIN). If the individual does not have and is not eligible for an SSN, they must apply for an ITIN by using Form W-7 .
Any person other than an individual, and any individual who is an employer or who is engaged in a U.S. trade or business as a sole proprietor, must have an employer identification number (EIN). If you don't have an EIN, you may apply for one online by going to IRS.gov/EIN . If you are outside the United States, you

may also apply for an EIN by calling 267-941-1099 (not a toll-free number). You may also apply for an EIN by faxing or mailing Form SS-4 to the IRS.

Caution: Under certain circumstances, an FI may be required to get a GIIN for purposes of chapter 4. See Global Intermediary Identification Numbers, later. See the Instructions for Form 8957 for information on whether a GIIN is needed.

A U.S. or foreign TIN (as applicable) must generally be on a withholding certificate if the beneficial owner is claiming any of the following.

Tax treaty benefits (see Exceptions to U.S. TIN re- quirement, later).
Income is effectively connected with a U.S. trade or business.
Exemption for certain annuities (see Pensions, Annui- ties, and Alimony, earlier).
Exemption based on exempt organization or private foundation status.

A foreign TIN may also be required for certain account holders (see Foreign TIN requirement for account holders , later). In addition, a U.S. TIN must be on a withholding certificate from a person claiming to be any of the following.

QI (including when acting as a QDD).
QSL.
WP.
WT.
An organization claiming an exemption or reduced rate of withholding based solely on a claim of tax-exempt status under section 501(c) or private foundation status (unless only the 4% tax under section 4948(a) applies to the private foundation).
U.S. branch of a foreign person treated as a U.S. person (see Regulations section 1.1441-1(b)(2)(iv)), and a U.S. branch of an FFI acting as an intermediary that is not treated as a U.S person.
U.S. person.

Exceptions to U.S. TIN requirement. A foreign person does not have to provide a U.S. TIN to claim a reduced rate of withholding under a tax treaty if the requirements for the following exceptions are met. Instead of requesting a U.S. TIN from a foreign payee, you may request a foreign TIN issued by the payee’s country of residence except when the payee is a nonresident alien individual claiming an exemption from withholding on Form 8233.

Income from marketable securities (discussed earlier under Beneficial Owners ).
Unexpected payment to an individual in the case of a payment made by a U.S. FI to an account maintained at a U.S. office (discussed next).

Unexpected payment. A Form W-8BEN or a Form 8233 provided by a nonresident alien to get treaty benefits does not need a U.S. TIN if you, the withholding agent, meet all the following requirements.

You are an acceptance agent.
You can request an ITIN for a payee on an expedited basis.
You are required to make an unexpected payment to the nonresident alien.
You cannot get the ITIN because the IRS is not issuing ITINs at the time you make the payment or at any earlier time after you know you have to make the payment.
You cannot reasonably delay making the unexpected payment.
You submit a completed Form W-7 for the payee, with a certification that you have reviewed the required documentation and have no actual knowledge or reason to know that the documentation is not complete or accurate, to the IRS during the first business day after you made the payment.

An acceptance agent is a person who, under a written agreement with the IRS, is authorized to help alien individuals and other foreign persons get ITINs or EINs. For information on the application procedures for becoming an acceptance agent, go to IRS.gov/AAPC .

Note: All acceptance agents will be required to adhere to new quality standards established and monitored by the IRS.

Publication 515 (2026) 59

A payment is unexpected if you or the beneficial owner could not have reasonably anticipated the payment during a time when an ITIN could be obtained. This could be due to the nature of the payment or the circumstances in which the payment is made. A payment is not considered unexpected solely because the amount of the payment is not fixed.

Example. Mary, a citizen and resident of Ireland, visits the United States and wins $5,000 playing a slot machine in a casino. Under the treaty with Ireland, the winnings are not subject to U.S. tax. Mary claims the treaty benefits by providing a Form W-8BEN to the casino upon winning at the slot machine. However, she does not have an ITIN or foreign TIN. The casino is an acceptance agent that can request an ITIN on an expedited basis.

Situation 1. Assume that Mary won the money on Sunday. Since the IRS does not issue ITINs on Sunday, the casino can pay $5,000 to Mary without withholding U.S. tax. The casino must, on the following Monday, fax a completed Form W-7 for Mary, including the required certification, to the IRS for an expedited ITIN.

Situation 2. Assume that Mary won the money on Monday. To pay the winnings without withholding U.S. tax, the casino must apply for and get an ITIN for Mary because an expedited ITIN is available from the IRS at the time of the payment.

Foreign TIN requirement for account holders. If you are a U.S. office or branch of a depository institution, custodial institution, investment entity, or specified insurance company (each as defined in Regulations section 1.1471-5(e)) documenting an account holder (as defined in Regulations section 1.1471-5(a)(3)) of an account that is a financial account (as defined in Regulations section 1.1471-5(b)), you must obtain the account holder’s TIN for its jurisdiction of tax residence (foreign TIN) on a Form W-8 that is a beneficial owner withholding certificate in order for the form to not be invalid for a payment of U.S. source income reportable on Form 1042-S, unless:

The account holder is a resident of a jurisdiction that is not listed in section 3 of Revenue Procedure 2021-32, 2021-42 I.R.B. 465, available at IRS.gov/irb/ 2021-42_IRB#REV-PROC-2021-32 , which may be

further updated in future published guidance;

The account holder is a resident in a jurisdiction that has been identified by the IRS on a list of jurisdictions that do not issue foreign TINs. See IRS.gov/ NoForeignTIN ;
The account holder is a government, international organization, foreign central bank of issue, or resident of a U.S. territory; or
The account holder obtains a reasonable explanation for why the account holder has not been issued a foreign TIN, including by checking the applicable box on the applicable Form W-8 indicating that the account holder is not legally required to obtain an FTIN from the account holder’s jurisdiction of residence (including if the jurisdiction does not issue TINs).

A reasonable explanation that an account holder does not have a foreign TIN must address why the account holder was not issued a foreign TIN to the extent provided in the instructions for the applicable Form W-8. If an account holder provides an explanation other than the one described in the instructions for the applicable Form W-8, you must determine whether the explanation is reasonable.