Ezel / IRS Rulings / 201520011
Chief Counsel Advice 201520011 Released May 15, 2015 Advice

No direct penalty applies to failure to update EIN information

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This page covers one taxpayer's ruling from 2015, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

Currency note: this determination was released in 2015
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

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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