# ITIN Application — Sungho Park

## Status

- [ ] Engage a Certifying Acceptance Agent (CAA)
- [ ] Sungho Park completes video interview with CAA
- [ ] Submit Form W-7 application
- [ ] Receive ITIN (7–11 weeks)

---

## What

Individual Taxpayer Identification Number (ITIN) for Sungho Park. Required because he is a foreign national not eligible for a Social Security Number but must file US tax documents as a partner in a US partnership.

---

## Why Required

- Palace Fund LLC files Form 1065 (partnership tax return) annually
- Each member receives a Schedule K-1 showing their share of fund income
- Without an ITIN, the IRS requires **30% backup withholding** on all distributions
- With an ITIN, withholding drops to 21% (§1446) on ECI only, and the US-Korea tax treaty further reduces or eliminates tax on capital gains from securities
- ITINs are required to claim treaty benefits on Form 8833

---

## How to Get ITIN

Sungho Park is in Korea — he cannot visit an IRS Taxpayer Assistance Center in person. He must use a **Certifying Acceptance Agent (CAA)**.

1. Find a CAA who does video interviews (many US CPAs and attorneys qualify)
   - IRS CAA directory: https://www.irs.gov/individuals/international-taxpayers/acceptance-agents-foreign-applicants-for-individual-taxpayer-identification-numbers
2. CAA reviews original passports via video — does not require mailing passports
3. CAA certifies the passport copies and submits Form W-7 to IRS
4. IRS issues ITIN in 7–11 weeks

---

## Cost

~$200–400 (CAA fee, one person).

---

## Documents Needed

- Korean passport (original — reviewed via video by CAA)
- Form W-7 (IRS application — CAA helps complete)
- Supporting document showing reason for ITIN: a copy of the Palace Fund LLC Form 1065 or a letter from the fund stating he is a partner

---

## Timing

Start this process as soon as the OA is signed and Sungho Park is formally a member. The 7–11 week timeline means you want to apply well before the first tax filing is due.

---

## Notes

- ITIN ≠ Social Security Number — it is for tax purposes only
- ITIN does not affect immigration status
- ITINs expire if not used on a US tax return for 3 consecutive years — renew if needed
- Sungho Park is the sole LP member