Can an authorized representative be the responsible party on an EIN application?

An authorized representative can complete the EIN application, but they can’t be the responsible party unless they have ultimate control over the entity.

According to IRS instructions, the responsible party is the individual who ultimately owns or controls the entity or exercises effective control. An authorized representative, like an attorney or CPA, can sign the form but must list the true responsible party, who must be an individual with control, not just someone acting on behalf of the entity.

The answer is no, an authorized representative cannot be the responsible party unless they have ultimate control over the entity. They can sign the EIN application, but they don’t fulfill the role of the responsible party if they aren’t in control. The IRS specifically requires the responsible party to be the individual with the highest level of control, who owns or manages the entity — and it must be a natural person, not just a representative.

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