1. Introduction: What is Form 15118?
IRS Form 15118, officially titled Response to Notice CP562A, is an administrative response document published by the Internal Revenue Service (IRS). It is governed by the Wage and Investment Division of the IRS and processed exclusively by the specialized Adoption Taxpayer Identification Number (ATIN) Unit at the IRS Austin Service Center.
This form is not a standard tax return that you file during annual tax season. Instead, the IRS sends Form 15118 enclosed with Notice CP562A to prospective adoptive parents who submitted Form W-7A (Application for Taxpayer Identification Number for Pending U.S. Adoptions) when the application cannot be processed due to missing signatures, unverified parent Social Security numbers, name mismatches, or missing child placement documentation. It provides a formal legal avenue for adoptive parents to provide missing records so the IRS can issue a temporary tax identification number for their child.
2. Purpose of the Form: Why Does Form 15118 Exist?
When a child is placed in a home for domestic adoption, the legal process often takes months or years to finalize. During this interim period, adoptive parents cannot obtain an official Social Security card for the child from the Social Security Administration, and state adoption agencies keep birth records confidential. To allow parents to claim dependency benefits and adoption credits on their tax returns, the IRS issues a temporary nine-digit ATIN via Form W-7A.
Because federal tax law strictly regulates who can claim adoption benefits, the IRS enforces rigorous verification rules before issuing an ATIN. When an application lacks required paperwork or contains mismatched data, the IRS does not simply reject it outright. Form 15118 exists to solve this problem:
- Curing Application Deficiencies: It allows parents to provide missing items—such as omitted signatures or placement agreements—without paying new application fees or restarting the process from scratch.
- Reconciling Social Security Name Discrepancies: It provides a mechanism for parents to explain why their name on Form W-7A does not match Social Security Administration records (e.g., due to a recent marriage, divorce, or professional name change).
- Speeding Up ATIN Issuance: Returning Form 15118 within the allowable window keeps your original Form W-7A application active, ensuring your child receives an ATIN in time for annual tax filing deadlines.
3. Who Needs to File This Form?
Form 15118 is an inquiry-driven document that you only complete if you receive an official notice from the IRS. You need to complete and submit Form 15118 if:
- You submitted Form W-7A to obtain an Adoption Taxpayer Identification Number for a child legally placed in your home for domestic adoption.
- You received IRS Notice CP562A stating that your Form W-7A application was incomplete or could not be processed.
- One or both adoptive parents failed to sign the original Form W-7A application.
- The IRS reported that a parent’s name or Social Security Number did not match Social Security Administration database records.
- You failed to attach acceptable third-party legal placement documentation proving the child was placed with you for legal adoption.
4. Who Is Exempt / Not Required to File?
Many adoptive families and general taxpayers have no reason to use Form 15118. You are exempt or not required to submit it under the following conditions:
- Approved Form W-7A Filers: If your initial Form W-7A was complete and approved without inquiry, you will receive Notice CP560 assigning your ATIN and will never see Form 15118.
- Child Already Has an SSN: If your child already has an official Social Security Number assigned by the Social Security Administration, you do not need an ATIN.
- Applying for an Initial ATIN: If you are applying for a new adoption tax ID for the first time, do not file Form 15118. You must complete and file Form W-7A instead.
- Extending an Expiring ATIN: If you already have an active ATIN that is approaching its two-year expiration date, you must file Form 15100 (ATIN Extension Request) rather than Form 15118.
- International Adoptions: Children adopted abroad who are not U.S. citizens or resident aliens do not qualify for an ATIN; they must obtain an Individual Taxpayer Identification Number (ITIN) using Form W-7.
5. When to File: Deadlines and Frequency
Form 15118 is an event-based response document rather than an annual recurring filing. It carries a firm administrative deadline printed on the accompanying notice.
Notice CP562A allows taxpayers 60 calendar days from the date of the notice to submit Form 15118 and all requested supporting documents. Meeting this 60-day deadline is critical: if you fail to respond on time, the IRS will officially reject your Form W-7A application as incomplete. If your application is rejected, you will be forced to reapply from the beginning, which can delay your child’s tax ID and prevent you from claiming adoption benefits on your upcoming tax return.
6. Where and How to File
Form 15118 cannot be submitted through commercial tax preparation software. The IRS provides several dedicated channels to submit your response directly to the ATIN processing unit:
- IRS Document Upload Tool (Fastest Method): Check your Notice CP562A for a unique, secure access code and website link. You can scan or photograph Form 15118 and your placement documents and upload them digitally through the official Document Upload Tool on a computer or mobile phone.
- Submission by Facsimile (Fax): You can fax the completed form and supporting legal records directly to the dedicated IRS ATIN fax number printed on Notice CP562A (typically 855-250-1731). Always retain your transmission confirmation report.
- Submission by Mail: Complete the paper form, attach your placement documentation, and mail it using the return envelope provided, or send it to the designated IRS address as per instructions printed on Notice CP562A (Internal Revenue Service, Stop 6182, Austin, TX 73301-0066). Always send via certified mail with tracking.
- Never Send Original Documents: Always submit clear, readable photocopies of placement contracts, birth certificates, or court orders. The IRS does not guarantee the return of original documents.
7. Step-by-Step Instructions to Fill Form 15118
Form 15118 is a two-page document designed to address the specific reasons your Form W-7A was paused. You only need to complete the sections specifically flagged on your Notice CP562A. The table below outlines each section of the form.
| Section / Page | Item Name | Required Information & Instructions |
|---|---|---|
| Page 1 | Missing Signatures Block | Original signatures, daytime phone numbers, and dates for Adoptive Parent 1 and Adoptive Parent 2. |
| Page 1 | Child & Placement Data | Child’s legal name, date of birth, and official placement agency contact information. |
| Page 2 | SSN / Name Discrepancies | Parent full legal name, SSN, and written explanation of name differences (marriage, divorce, legal action). |
| Page 2 | Name Change Evidence | Checklist verifying attached legal proof of parent name change (marriage certificate, divorce decree). |
| Page 2 | Contact Information Change | Updated street address, city, state, ZIP code, telephone number, and best time to call (a.m. or p.m.). |
Part 1: Missing Application Signatures (Page 1)
If your Notice CP562A states that your Form W-7A was unsigned, both adoptive parents must sign and date the signature section on Page 1. If two people are adopting the child, both parents must sign in ink. By signing, you declare under penalties of perjury that you have examined the application and that all statements and attached placement records are true, correct, and complete. Provide a daytime telephone number for each parent.
Part 2: Child and Placement Agency Information (Page 1)
If your notice requested additional information regarding the child or agency, provide the child’s full legal name as used for the adoption, their date of birth, and the full name, address, and telephone number of the authorized child placement agency or adoption attorney handling the case.
Part 3: Parent Social Security Number and Name Mismatches (Page 2)
This section is used when the name or SSN you entered on Form W-7A does not match Social Security Administration (SSA) records. This frequently occurs if an adoptive parent recently married, divorced, or used a maiden or professional name that was never updated with the SSA:
- Enter the parent’s nine-digit Social Security Number and full legal name as it appears on their Social Security card.
- Provide a clear written explanation of the discrepancy (e.g., “I recently married and have not yet updated my surname with the Social Security Administration”).
- Attach a clear photocopy of the legal document supporting the name change (such as an official marriage certificate, divorce decree, or court-ordered name change decree).
Part 4: Change in Contact Information (Page 2)
If your family moved since submitting Form W-7A, provide your new residential street address, city, state, ZIP code, and current telephone number. Indicate whether morning or afternoon is the best time to call if an IRS technician needs to clarify your response.
8. Required Documents and Information Needed Before Filling
Before completing Form 15118, assemble the following records based on the specific issues flagged in Notice CP562A:
- The original Notice CP562A received from the IRS.
- A copy of your originally submitted Form W-7A.
- Legal Adoption Placement Documentation (One of the Following):
- A signed and dated placement agreement between you and an authorized child placement agency.
- A hospital release document signed by a hospital official authorizing the release of a newborn directly to you for legal adoption.
- A court order or decree approving the placement of the child with you for legal adoption.
- A formal affidavit signed by the adoption attorney or government official who placed the child with you pursuant to state law.
- Proof of legal parent name change (marriage license, divorce decree) if responding to an SSN mismatch.
- Permanent resident card (green card), Certificate of Citizenship, or passport if adopting a foreign-born child who already holds U.S. citizenship or resident alien status.
9. Common Mistakes to Avoid
Errors on Form 15118 can cause your application to be rejected, leaving you without a tax ID for your child. Watch out for these frequent mistakes:
- Missing the Second Parent’s Signature: If two adoptive parents are listed on the adoption application, both parents must sign Form 15118 in ink. Submitting a form with only one signature is the number one reason responses are delayed.
- Submitting Foster Care Documents: An ATIN is legally restricted to children placed for legal adoption. Submitting temporary foster care agreements or kinship placement paperwork that does not specify placement for legal adoption will result in immediate denial.
- Mailing Original Documents: Never send original court decrees, marriage licenses, or hospital release letters. The IRS does not return submitted documentation; send clear photocopies only.
- Failing to Update the Social Security Administration: If your name does not match SSA records, submitting Form 15118 with a marriage license resolves the ATIN issue, but you must still contact the SSA (using Form SS-5) to officially update your Social Security card for future tax returns.
- Missing the 60-Day Response Window: Failing to submit Form 15118 within 60 calendar days causes the IRS to close and reject your Form W-7A file.
10. Penalties for Non-Filing or Errors
Because Form 15118 is an application response document rather than a tax return, there are no direct fines for failing to file it. However, the indirect financial consequences are substantial:
- Rejection of Form W-7A: If you ignore Notice CP562A, your application is formally rejected. Your child will not be assigned an ATIN, leaving you without an identification number for tax filing season.
- Loss of High-Value Tax Benefits: Without an active ATIN or SSN, you cannot claim the child as a dependent, claim the Adoption Tax Credit (worth over $16,000 in qualifying expenses), or claim the Child and Dependent Care Credit.
- Electronic Tax Return Rejections: Tax software will reject electronic tax returns that list a child without an active tax identification number, forcing you to file paper returns and delaying your tax refund for months.
- Perjury Consequences: Form 15118 is signed under penalties of perjury. Falsifying adoption placement documents or claiming children who were not placed with you for legal adoption is a federal crime punishable under 26 U.S.C. Section 7206.
11. Related Forms or Schedules
Form 15118 operates within a specialized collection of adoption and taxpayer identification forms:
- Form W-7A: Application for Taxpayer Identification Number for Pending U.S. Adoptions (the original application).
- Notice CP562A: Notice of Incomplete Form W-7A (the triggering notice).
- Form 15100: Adoption Taxpayer Identification Number (ATIN) Extension Request.
- Form 15101: Provide a Social Security Number (SSN) for Adoptive Child.
- Form 8839: Qualified Adoption Expenses.
- Form 2441: Child and Dependent Care Expenses.
- Form SS-5: Application for a Social Security Card (Social Security Administration).
12. Frequently Asked Questions (FAQs)
1. Why did I receive Notice CP562A and Form 15118?
The IRS sent Notice CP562A and Form 15118 because your application for an adoption tax ID (Form W-7A) was missing essential information—such as a parent’s signature, legal placement documentation, or a matching name and Social Security Number with the Social Security Administration.
2. What documents prove a child was placed for legal adoption?
Acceptable documents include a signed placement agreement from an authorized adoption agency, a hospital document signed by a hospital official releasing a newborn to you for legal adoption, a court order approving placement for adoption, or an affidavit signed by an adoption attorney pursuant to state law.
3. What if my last name does not match Social Security Administration records?
On Page 2 of Form 15118, enter your full legal name, Social Security Number, and explain the reason for the mismatch (such as a recent marriage or divorce). You must attach a photocopy of the legal document that supports the name change, such as a marriage certificate or court decree.
4. What happens if our child received an SSN while waiting for Form W-7A?
If the Social Security Administration assigned an SSN while your ATIN application was pending, you no longer need an ATIN. You can write the newly assigned SSN on Form 15118 and return it to the IRS so they can close the W-7A request, and you can begin using the permanent SSN on your tax returns.
5. Can I use foster care placement documents to satisfy Form 15118?
No. Standard foster care placement documents do not qualify for an ATIN. The documentation must explicitly state that the child has been placed with you for the specific purpose of legal adoption.
6. How long does the IRS take to issue an ATIN after receiving Form 15118?
Once the IRS ATIN Unit receives your completed Form 15118 and verified placement documents, it typically takes 4 to 6 weeks to process the application and mail Notice CP560 containing your child’s official nine-digit ATIN.
13. Conclusion: Key Takeaways
IRS Form 15118 is a critical administrative tool that keeps your adoption tax identification process moving forward. When the IRS identifies missing paperwork on Form W-7A, responding to Notice CP562A with Form 15118 ensures that your child’s temporary tax ID is approved without forcing you to restart the application from scratch.
Because missing the 60-day response deadline results in application rejection and delays your family tax benefits, adoptive parents should compile their placement records, provide original ink signatures from both parents, and upload Form 15118 using the IRS Document Upload Tool or send it via certified mail immediately upon receiving Notice CP562A.