No direct penalty applies to failure to update EIN information

Plain-English summary

Chief Counsel addressed the requirement that a person issued an employer identification number provide updated application information when required by forms, instructions, or other guidance. The advice states that there was no directly applicable penalty for failing to provide the update. It did not say that the underlying update requirement was optional. The conclusion was limited to whether noncompliance itself carried a direct penalty.

Ruling snapshot

• Question: Is there a directly applicable penalty for failing to update EIN application information?
• Outcome: Advice given, no directly applicable penalty existed.
• Key authorities: Treas. Reg. § 301.6109-1(d)(2)(ii)

Full text (IRS public release)

ID: CCA_2015042415060710
UILC: 6109.03-00

Number: 201520011
Release Date: 5/15/2015
From:
Sent: Friday, April 24, 2015 15:06:07
To:
Cc:
Bcc:
Subject: EIN updating & penalties

You asked whether the requirement in Treas. Reg. § 301.6109-1(d)(2)(ii) that persons issued EINs provide any updated application information as required by forms, instructions, or other guidance carries penalties for non-compliance. There are currently no directly-applicable penalties for failure to update this information.

Thanks,
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