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Identity Protection PIN Available to ALL Taxpayers in January

Client Alert

Beginning in January 2021, the IRS will allow all taxpayers who can properly verify his/her identity to obtain an Identity Protection PIN. An Identity Protection PIN (“IP PIN”) is a six-digit number assigned to a specific taxpayer to assist in preventing the misuse of a taxpayer’s social security number on fraudulent federal tax returns. Previously, only confirmed victims of identity theft who resolved his/her tax issues with the IRS were eligible for an IP PIN.

Eligibility

To be eligible for the IP PIN Opt-in Program, a taxpayer must pass a rigorous identity verification process. Spouses and dependents are eligible for an IP PIN if he/she can also pass the identity verification process.

How to get an IP PIN

In order to participate in the IP PIN Opt-in Program, a taxpayer may apply online, mail in Form 15227, or in certain circumstances, may make an in-person appointment.

Applying online

Taxpayers who apply online should use the “Get an IP PIN” tool on the IRS website. The taxpayer will need to create an account on IRS.gov if one has not already been created previously. When creating an account, the taxpayer should have the following readily accessible:

  • Email address
  • Social Security Number
  • Tax filing status and mailing address
  • One financial account number linked to the taxpayer’s name such as:
    • Credit card
    • Student Loan
    • Mortgage
    • Home Equity Line of Credit
    • Auto Loan
  • Mobile phone linked to the taxpayer’s name or the ability to receive an activation code by mail

Once logged in to the Get an IP Pin tool, the taxpayer’s IP PIN will be immediately displayed.

Applying by mail

Taxpayer’s whose income is $72,000 or less may complete Form 15227, Application for an Identity Protection Personal Identification Number. This Form may be mailed or faxed to the IRS and will be available in January 2021. After receipt, an IRS employee will call the taxpayer to verify his/her identity using a series of questions. If the taxpayer successfully verifies his/her identity, an IP PIN will be assigned for the following tax year. If a taxpayer chooses to file a Form 15227, caution should be used when the IRS agent calls to ensure the caller is not a scammer.

Applying in-person

For taxpayer’s who cannot verify his/her identity remotely or are ineligible to file Form 15227, an in-person appointment at a Taxpayer Assistance Center may be made. The taxpayer should take two forms of picture identification with them to the appointment. If the taxpayer successfully verifies his/her identity at the in-person appointment, the IRS will mail an IP PIN to him/her within three weeks.

Things to Know if an IP PIN is issued

Taxpayer’s should be aware of that IP PINs are only valid for one year. Each January, the taxpayer must obtain a new IP PIN. IP PINs must also be entered correctly on the federal tax return or the return may be rejected or delayed

For additional questions related to the identity theft and the IP PIN program, please contact BMD Tax Law Attorney Tracy Albanese at tlalbanese@bmdllc.com or (330) 253-9195.


Corporate Transparency Act to be Re-evaluated

Recent federal rulings have impacted the enforceability of the Corporate Transparency Act (CTA), which took effect on January 1, 2024. While reporting requirements were briefly reinstated, FinCEN has now paused enforcement and is reevaluating the CTA. Businesses are no longer required to submit reports until further guidance is issued. For updates and legal counsel, contact BMD Member Blake Gerney.

Ohio Recovery Housing Operators Beware: House Bill 58 Seeks to Make Major Changes

Ohio House Bill 58 proposes significant changes to recovery housing oversight, granting ADAMH Boards authority to inspect and investigate recovery residences. The bill also introduces a Certificate of Need (CON) program, requiring state approval for major facility changes. OMHAS will assess applications based on cost, quality, accessibility, and financial feasibility. The bill also establishes a recovery housing residence fund to support inspections. For more information, contact BMD attorneys Daphne Kackloudis or Jordan Burdick.

January 2025 Notice of Proposed Rulemaking Brings Notable Changes to HIPAA Security Rule

In January 2025, the U.S. Department of Health and Human Services proposed amendments to the HIPAA Security Rule, aiming to enhance cybersecurity for covered entities (CEs) and business associates (BAs). Key changes include mandatory compliance audits, workforce training, vulnerability scans, and risk assessments. Comments on the proposed rule are due by March 7, 2025.

Corporate Transparency Act Effective Again

The federal judiciary has issued multiple rulings on the enforceability of the Corporate Transparency Act (CTA), which took effect on January 1, 2024. Previously, enforcement was halted nationwide due to litigation in Smith v. U.S. Department of the Treasury. However, on February 18th, the court lifted the stay, reinstating the CTA’s reporting requirements. Non-exempt entities now have until March 21, 2025, to comply. Businesses should act promptly to avoid civil penalties of $591 per day and potential criminal liability.

Status Update: Physician Noncompete Agreements in Ohio

Noncompete agreements remain enforceable in Ohio if they meet specific legal requirements. While the AMA and FTC have challenged these restrictions, courts continue to uphold reasonable noncompete provisions for physicians. Recent cases, like MetroHealth System v. Khandelwal, highlight how courts may modify overly restrictive agreements to balance employer interests with patient care. With ongoing legal challenges to the FTC’s proposed ban, Ohio physicians should consult a healthcare attorney before signing or challenging a noncompete agreement.