Can Chinese, Russian, or Iranian Residents Apply for a U.S. ITIN?

A question that comes up regularly: "My country has sanctions with the U.S. — can I still apply for an ITIN?"

Or: "I'm from China — does that affect my eligibility?"

The short answer is that ITIN eligibility is determined by your U.S. tax obligations, not your country of citizenship or residence. But there are important country-specific nuances — particularly for Russian residents who have lost treaty benefits, and for individuals in countries under the strictest U.S. sanctions regimes.

What Determines ITIN Eligibility

The IRS issues ITINs to any individual who:

1. Has a U.S. tax filing obligation or a valid need for a TIN (such as a W-7 exception), and
2. Is not eligible for a Social Security Number

Citizenship is not a criterion. Country of residence is not a criterion. Whether your government has political tensions with the U.S. is not a criterion.

What matters: do you have a reason under the IRS rules to obtain a TIN? If yes, you can apply, from any country.

China: No Barrier to ITIN

China is not subject to OFAC financial sanctions in the context of individual tax filings. Chinese residents apply for ITINs routinely — for LLC ownership, investment income, e-commerce platforms, and U.S. bank accounts.

Common situations for Chinese applicants:

• Owners of U.S. single-member LLCs (Exception 5 / TD9363)
• Holders of U.S. stocks receiving dividends (Form 1042-S / 1040-NR)
• Chinese investors receiving U.S. rental income
• Parents in China receiving U.S. bank interest held for their children's education

The U.S.-China tax treaty is still in effect (as of 2026). Under the treaty, certain income types receive reduced withholding rates — but only if claimed properly with a TIN. This is another strong reason for Chinese applicants to obtain an ITIN.

Passport: Chinese passports are accepted by the IRS. A valid (unexpired) Chinese passport is sufficient for identity verification via a CAA.

Sanctions note: While certain Chinese entities and individuals appear on OFAC sanctions lists (such as defense companies or government officials), ordinary Chinese residents are not subject to U.S. sanctions that would affect IRS filings. If you are uncertain about your personal OFAC status, consult a sanctions compliance attorney.

Russia: ITIN Still Possible, But Treaty Benefits Are Gone

Russian residents can apply for ITINs. The IRS does not refuse ITIN applications based on Russian citizenship or residence.

However, the Russia-U.S. tax treaty was suspended in March 2024. Russia unilaterally suspended the treaty, and the U.S. reciprocated. This has significant practical implications:

• No reduced withholding rates: Russian residents can no longer claim reduced treaty rates on dividends (previously 5–10%), interest (previously 0%), royalties (previously 0%), or pension distributions (previously reduced rates).
• Default 30% withholding applies: All U.S.-source income paid to Russian residents is now subject to the full 30% statutory withholding rate.
• You can still obtain an ITIN: The treaty suspension affects tax rates, not ITIN eligibility. Filing obligations remain, and ITINs are still issued.
• You can still file Form 1040-NR: Even without treaty benefits, a 1040-NR may be required if you have effectively connected income, or may be filed to confirm that withholding was applied correctly.

Practical impact: For a Russian resident with U.S. LLC income or investment income, the absence of treaty protection means higher U.S. tax. Getting an ITIN is still useful for compliance (Form 5472, 1040-NR), even if the tax savings from treaty claims are unavailable.

Iran, Cuba, North Korea, Syria: OFAC Sanctions and Their Scope

These countries are subject to the most comprehensive U.S. sanctions programs administered by OFAC (Office of Foreign Assets Control). The sanctions are broad and affect financial transactions, trade, and certain services.

What OFAC sanctions generally prohibit:

• Financial transactions with sanctioned persons and entities
• Providing services to sanctioned persons
• Receiving payments from the U.S. to sanctioned countries

What OFAC sanctions do not prohibit:

• IRS tax filings and official U.S. government interactions
• Applying for a taxpayer identification number for legitimate tax purposes

The ITIN application itself — submitting Form W-7 to the IRS — is a filing with the U.S. government, not a commercial financial transaction. OFAC sanctions are generally not interpreted as prohibiting tax compliance with the IRS.

Practical complications for heavily sanctioned countries:

1. Passport: Passports from sanctioned countries are generally accepted for ITIN purposes, but some CAA services may decline to work with applicants from these countries due to their own compliance programs. The IRS itself does not exclude passport holders from sanctioned countries.
2. Refund receipt: If you file Form 1040-NR and are owed a refund, the IRS issues a check. Depositing a U.S. government check in a sanctioned country involves banking complications that go beyond the tax filing itself.
3. CAA access: Finding a CAA willing to work with applicants in severely sanctioned countries can be difficult. Many CAA services restrict their geographic scope for compliance reasons.
4. Bank accounts: If your ITIN use case involves a U.S. bank account or financial platform, opening or maintaining that account as a resident of a sanctioned country involves OFAC compliance that is separate from and more restrictive than the ITIN rules.

If you're in a heavily sanctioned country and have a genuine U.S. tax obligation, consult both a tax professional and a sanctions compliance attorney before proceeding.

Middle East and Other Regions Without Sanctions

Most countries in the Middle East, Africa, Southeast Asia, and elsewhere are not subject to OFAC sanctions at the individual level. Saudi Arabia, UAE, Egypt, Pakistan, Bangladesh, Nigeria, and the vast majority of other countries — residents of these countries apply for ITINs routinely.

The relevant question for these applicants is not sanctions but rather:

• Do you have a valid reason for an ITIN? (U.S. LLC, U.S. income, filing as a dependent, etc.)
• Do you have a valid passport for identity verification?
• Does your country have a U.S. tax treaty that affects your withholding rates?

Common treaty countries with favorable rates: UK, Germany, France, India, Japan, South Korea, Australia, Canada, Netherlands, and many others. See IRS Publication 901 for a full treaty table.

Countries Without a U.S. Tax Treaty

Many countries — including many in Africa, parts of Southeast Asia and the Middle East — have no U.S. tax treaty with the United States. The lack of a treaty doesn't affect ITIN eligibility; it just means the default 30% withholding rate applies to most U.S.-source income, with no reduction.

Residents of non-treaty countries who have U.S.-source income (LLC income, dividends, rental income) should factor the 30% withholding rate into their planning. An ITIN is still needed for Form 1040-NR filing to report income, claim credits for withheld amounts, and remain compliant.

Summary: Country-by-Country Quick Reference

Wherever you're located, if you have a U.S. tax obligation, we can help. [Contact us](/apply) to discuss your situation.