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Citizenship Issues: Handling Situations for Applicants
with Undocumented Parents
Citizenship Issues: Handling Situations for Applicants
with Undocumented Parents
NCASFAA/SCASFAA ConferenceAsheville, NC – November 2006
Anthony JonesGinger Klock
U.S. Dept. of Education
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Agenda
Policy Issues/Real World Scenarios– Reporting/Verifying Income– Paperwork– SSN Issues– PLUS/Additional Unsubsidized Eligibility– Title IV Assistance for Victims of Human
Trafficking
Processing Citizenship and SSN Matches
Discussion/Questions
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Policy Issues Related to Undocumented Parents
Citizenship Rules and Regulations Reporting Income Verifying Income PLUS Eligibility/Additional Unsubsidized
Loan Eligibility Citizenship or Resident Paperwork
Issues Parent Social Security Number Issues Victims of Human Trafficking
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Citizenship Rules for Title IV
Section 484(a)(5) of the HEA
34 CFR 668.32(d), .33, and Subpart I, as well as 682.201(b)(1)(i) and 685.200(b)(1)(iii)
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Citizenship Rules for Title IV
- continued
A student or borrower must be:– U.S. citizen or national;– U.S. permanent resident;– Citizen of the Freely Associated
States, the Federated States of Micronesia, and the republics of Palau and the Marshall Islands; or
– Other eligible non-citizen
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Citizenship Rules (IRS)
IRS Publication 519: Includes a chart for determining resident vs.
nonresident status for IRS purposes– Resident alien’s income is generally subject to
tax in the same manner as a U.S. citizen
– Nonresident alien’s income is usually subject to U.S. income tax only on U.S. source income
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Citizenship Rules (IRS) – continued
IRS Publication 519 - continued:
A taxpayer identification number (TIN) must be on a return (usually the SSN). If you do not have an SSN, you must apply for an individual TIN.
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Undocumented Worker: Reporting Income
If parent of dependent applicant is an undocumented worker, parent(s) must still supply income and asset information
Same rules apply if applicant is undocumented but will probably run into citizenship match issues
Cannot do dependency override solely because parent is undocumented worker and concerned about status being revealed (similar to any parent who refuses to supply information)
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Undocumented Worker: Verifying Income
Applicants with income above minimum threshold for filing must file a tax return. If they do not, it is conflicting information.
IRS provision allows undocumented workers to file tax return by applying for individual taxpayer ID number for tax return filing purposes only
• See IRS Publication 519, page 23
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Undocumented Worker: Verifying Income
- continued
If below minimum threshold for filing,
school can accept W2s or signed, dated
statement from parents verifying source(s)
and amount(s) of income (see 34 CFR
668.57(a)(4))
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Undocumented Worker: Paperwork Issues
Even if the student has a letter from DHS verifying that the parent’s application is in the processing stage, that letter is not acceptable as proof of eligibility for Title IV purposes
– Ultimately the application could be denied or deemed incomplete and unable to process
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Undocumented Worker: SSN Issues
When completing the FAFSA, a parent who legitimately does not have an SSN should supply all zeroes
– Leaving the item blank on paper will cause a rejected application
– FOTW will not allow blanks– Zeroes are considered a valid
response
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PLUS/Additional Unsubsidized Eligibility
Dear Colleague Letter GEN-05-16 (Q&A # 5):
An institution may award a dependent student additional unsubsidized Stafford loan amounts based on the fact that there are exceptional circumstances that preclude the parent from borrowing a PLUS
Can occur if dependent student’s parent is not a U.S. citizen or permanent resident (or is unable to provide official evidence that he/she is in U.S for other than a temporary purpose with the intention of becoming a citizen or permanent resident)
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Title IV Assistance for Victims of Human Trafficking
Section 107(b)(1)(A) of the Victims of Trafficking and Violence Protection Act (VTVPA) – an alien who is a victim of a severe form of trafficking
in persons shall be eligible for Federal benefits/services the same as a refugee
ED has long held that non-citizens with refugee status (according to section 207 of Immigration and Naturalization Act) are eligible for Title IV assistance as eligible non-citizens
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Title IV Assistance for Victims of Human Trafficking
- continued
See Dear Colleague Letter GEN-06-09 for complete details
FAFSA response to citizenship would be eligible non-citizen and an alien registration number must be provided– Will fail the DHS data match(es)
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Title IV Assistance for Victims of Human Trafficking
- continued
Documentation issued by the U.S. Department of Health and Human Services (HHS) – Certification Letter to a victim age 18 or older
– Eligibility Letter to a victim under the age of 18
FAA must call the HHS Office of Refugee Resettlement at 1-866-401-5510 to verify its validity and to confirm that HHS certification or eligibility has not expired
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Title IV Assistance for Victims of Human Trafficking
- continued
Relatives of Victims: The spouse, child, or parent of a victim of human trafficking may also be eligible for Title IV program assistance
FAFSA response to citizenship would be eligible non-citizen and an alien registration number must be provided– Will fail the DHS data match(es)
HHS documentation issued to relatives:– T-visa (T-2, T-3, or T-4, etc.)
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Title IV Assistance for Victims of Human Trafficking - continued
For the Relatives of Victims: The FAA must collect a copy of the applicant's T-visa AND a copy of the Certification Letter or Eligibility Letter issued to the victim
FAA must call the Office of Refugee Resettlement to establish both the validity of the victim's status and to confirm the validity of the applicant's T-visa
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CPS Data Matching Results
Match Flags are alpha or numeric codes that show the results of each match between the CPS and another database.
Comments and comment codes provide information to the student and to the FAA about the results of the processed FAFSA. Comments are included on the student’s SAR and on the EDExpress printed ISIR.
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Matching Results - continued
The “C” Code is an indicator that, even though an EFC was calculated, institutional resolution is required on the results of one or more of the database matches.
– “C” Codes must be resolved either by a correction being made or by the school collecting adequate documentation.
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Matching Results - continued
Rejects are triggered when applicant data is missing or seriously questionable or when the processing results are unacceptable. In all reject situations, an Expected Family Contribution (EFC) is not calculated, and no Title IV aid may be paid based on a rejected CPS record.
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Data Matches for Citizenship
• Sections 484(g) of HEA and 668.33 of the regulations provide that an applicant must be either a citizen or eligible non-citizen.
• Applicant records that go to DHS for the data match are those who indicate eligible non-citizen and provide an alien registration number on the FAFSA.
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DHS Primary Verification
"C" Code Match Flag Comment Resolution
no Y 143 no
Applicant’s non-citizen eligibility confirmed by DHS.
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DHS Primary Verification - continued
"C" Code Match Flag Comment Resolution
yes N 144 yes
DHS did not confirm applicant’s non-citizen eligibility.
See results from Secondary Confirmation.
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DHS Primary Verification - continued
"C" Code Match Flag Comment ResolutionReject 17 none 68 yes
Applicant did not indicate citizenship status. DHS match was not conducted.
If SSA Citizenship is verified – Reject 17 will be suppressed.
Applicant should correct to U.S. Citizen (or to eligible non-citizen and provide alien registration number (ARN)).
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DHS Primary Verification - continued
"C" Code Match Flag Comment Resolution yes none 141 yes
Applicant changed from eligible non-citizen to citizen or changed ARN.
DHS match not conducted. Determine why student changed information.
Student may need to submit proof of citizenship.
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DHS Primary Verification- continued
"C" Code Match Flag Comment Resolution yes none 142 yes
Student did not provide ARN or provided invalid ARN.
Match not conducted. Assist student to make SAR/ISIR correction to
provide valid ARN.
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DHS Secondary Confirmation
For applicants that fail Primary Verification:
CPS waits for three compute days to receive results from Secondary Confirmation instead of processing ISIRs with results from primary verification only.
If, after three days DHS does not return a response, CPS will generate the ISIR, which will show that Secondary Confirmation is still in progress.
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DHS Secondary Confirmation - continued
"C" Code Match Flag Comment Resolution no P none no
Automated secondary confirmation in progress. Wait at least five, but no more than 15 business
days for CPS system-generated ISIR with results of automated secondary confirmation.
If no response within 15 days, begin paper (G-845S) secondary confirmation.
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DHS Secondary Confirmation - continued
"C" Code Match Flag Comment Resolution
no Y 120 no
DHS confirmed student is an eligible non-citizen.
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DHS Secondary Confirmation - continued
"C" Code Match Flag Comment Resolution yes C 105 yes
In Continuance. School is encouraged, but not required, to wait ten business days for another systems generated ISIR with updated secondary confirmation match flag before beginning mandatory paper (G-845S) secondary confirmation process.
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DHS Secondary Confirmation - continued
"C" Code Match Flag Comment Resolution yes N 46 yes
DHS did not confirm eligibility. Must begin paper (G-845S) secondary
confirmation process.
G-845S
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DHS Secondary Confirmation - continued
"C" Code Match Flag Comment Resolution yes X 109 yes
DHS did not confirm eligibility because additional information is needed.
Must begin paper (G-845S) secondary confirmation process.
G-845S
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Notes on DHS Secondary Confirmation
Before sending copies of documentation to DHS, school should confirm:– student identifiers are correct, – especially alien registration number and – date of birth. – Make corrections to CPS as necessary.
If school does not receive a response to paper secondary confirmation in 15 days, – applicant is eligible for aid if documentation appears
to support claim of eligible non-citizen.
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Social Security Administration
Citizenship Status
"C" Code Match Flag Comment Resolution
no A or “blank” none no
SSA confirmed U.S. Citizenship status.
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Social Security Administration
Citizenship Status - continued
"C" Code Match Flag Comment Resolution yes B, C, D, E, F, or * 146 yes
SSA did not confirm U.S. citizenship status. If DHS confirmed citizenship status, comment 146
and C code will be suppressed. Student should provide birth certificate, passport, or
other documents that definitively prove citizenship.
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Social Security Administration
Citizenship Status - continued
A match flag of * (asterisk) generally indicates that the student was born in a foreign country to American parents that were stationed in another country (e.g., military, State Department, or Foreign Service). – These students generally have a birth certificate
indicating that they are U.S. Citizens that were born abroad.
– SSA will not automatically update this flag and the financial aid administrator should document the information in the student’s record.
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Social Security Administration
Citizenship Status - continued
"C" Code Match Flag Comment Resolution no N 62 yes
SSA unable to verify citizenship because there
was no match on SSN, name, or date of birth. Help student make corrections to social security
number, name, or date of birth if necessary so that the student’s record can be sent back to SSA for matching.
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Data Matching for Social Security Number with SSA
• Section 484(p) of HEA and section 668.36 of the regulations require a match with the Social Security Administration (SSA) to confirm the social security number of the applicant (and the parent(s) of a dependent applicant).
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Social Security Number Match with SSA
CPS matches with SSA to verify student and parents’ SSN, Name and DOB
Match flags are provided for the applicant and each parent
Comment text and codes are provided Preliminary guidance on resolution
provided No “C” codes for parents
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Social Security Number Match Results
SSA Match Flags: 1 = No match on SSN 2 = SSN & name match, no match on DOB 3 = SSN match, no match on name 4 = SSN, Name, and DOB match 5 = SSN, name, DOB match with Date of
Death 8 = Record not sent to SSA
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Parent Social Security Number Match with SSA -
continued
"C" Code Match Flag Comment ResolutionReject 6 Father = 1 11 yes Mother = not 4 Father’s SSN invalid at SSA. Mother’s match is either invalid SSN, mismatch on
name or on DOB. Neither parent has a full match of 4 Need to correct appropriate data elements for parents
to achieve a full match (for at least one parent).
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Parent Social Security Number Match with SSA
- continued
"C" Code Match Flag Comment Resolution Reject 7 Mother = 1 12 yes Father = not 4
Mother’s SSN invalid at SSA. Father’s match is either invalid SSN, mismatch on
name or on DOB. Neither parent has a full match of 4 Need to correct appropriate data elements for
parents to achieve a full match (for at least one parent).
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Parent Social Security Number Match with SSA -
continued
"C" Code Match Flag Comment Resolution no Father = 1 14 no Mother = 4 Father’s SSN invalid at SSA. Mother has a Full Match. Need to Correct SSN for Father to achieve a full
match.
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Parent Social Security Number Match with SSA -
continued
"C" Code Match Flag Comment Resolution no Mother = 1 15 no Father = 4 Mother’s SSN invalid at SSA. Father has a Full Match Need to correct SSN for Mother to achieve a
full match.
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Parent Social Security Number Match with SSA -
continued
"C" Code Match Flag Comment Resolution Reject S Father = 2 16 yes Mother = not 4 Father’s DOB invalid at SSA. Mother does not have a Full Match Need to correct DOB for Father to achieve a full
match. Need to correct Mother’s data elements as
appropriate to achieve full match.
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Parent Social Security Number Match with SSA -
continued
"C" Code Match Flag Comment Resolution no Father = 2 7 no Mother = not 4 Father reaffirmed that SSA’s invalid DOB is
correct. Mother does not have a Full Match Need to correct Mother’s data elements as
appropriate to achieve full match. If the Father’s DOB is correct, the father should
contact SSA to update its records.
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Parent Social Security Number Match with SSA -
continued
"C" Code Match Flag Comment Resolution Reject T Mother = 2 17 yes Father = not 4 Mother’s DOB invalid at SSA. Father does not have a Full Match. Need to correct DOB for Mother to achieve a full match. Need to correct Father’s data elements as appropriate
to achieve full match.
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Parent Social Security Number Match with SSA
- continued
"C" Code Match Flag Comment Resolution no Mother = 2 8 no
Father = not 4
Mother reaffirmed that SSA’s invalid DOB is correct.
Father does not have a Full Match. Need to correct Father’s data elements as
appropriate to achieve full match. If the Mother’s DOB is correct, the mother should
contact SSA to update its records.
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Parent Social Security Number Match with SSA -
continued
"C" Code Match Flag Comment Resolution no Father = 2 19 no Mother = 4
Father’s DOB invalid at SSA. Mother has a Full Match Need to correct Father’s DOB to achieve full
match.
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51
Parent Social Security Number Match with SSA
- continued
"C" Code Match Flag Comment Resolution no Mother = 2 21 no Father = 4
Mother’s DOB invalid at SSA. Father has a Full Match Need to correct Mother’s DOB to achieve full match.
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52
Parent Social Security Number Match with SSA
- continued
"C" Code Match Flag Comment Resolution no Father = 3 22 no Mother = 4 Father’s Name is invalid at SSA. Mother has a Full Match Need to correct Father’s name to achieve a full
match.
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53
Parent Social Security Number Match with SSA -
continued
"C" Code Match Flag Comment Resolution Reject E Father = 3 40 yes Mother = not 4 Father’s Name invalid at SSA. Mother does not have a Full Match Need to correct Name for Father to achieve a
full match. Need to correct Mother’s data elements as
appropriate to achieve full match.
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54
Parent Social Security Number Match with SSA -
continued
"C" Code Match Flag Comment Resolution no Father = 3 44 no Mother = not 4 Father reaffirmed that SSA’s invalid Name is correct. Mother does not have a Full Match Need to correct Mother’s data elements as appropriate
to achieve full match. If the Father’s Name is correct, the father should
contact SSA to update its records.
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55
Parent Social Security Number Match with SSA -
continued
"C" Code Match Flag Comment Resolution no Mother = 3 25 no
Father = 4 Mother’s Name is invalid at SSA. Father has a Full Match Need to correct Mother’s name to achieve a full
match.
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56
Parent Social Security Number Match with SSA -
continued
"C" Code Match Flag Comment Resolution Reject F Mother = 3 51 yes Father = not 4 Mother’s Name invalid at SSA. Father does not have a Full Match Need to correct Name for Mother to achieve a
full match. Need to correct Father’s data elements as
appropriate to achieve full match.
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57
Parent Social Security Number Match with SSA -
continued
"C" Code Match Flag Comment Resolution no Mother = 3 71 no Father = not 4 Mother reaffirmed that SSA’s invalid Name is correct. Father does not have a Full Match If the Mother’s Name is correct, the mother should
contact SSA to update its records. Need to correct Father’s data elements as appropriate
to achieve full match.
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58
Parent Social Security Number Match with SSA
- continued
"C" Code Match Flag Comment Resolution no Father = 5 27 no
Successful match to a deceased person’s
record on the SSA database for father. If the father’s identifiers are correct, the father
should contact SSA to fix their records. Once SSA corrects its records, the father can
reenter the name and submit it as a SAR/ISIR correction for an updated match flag.
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59
Parent Social Security Number Match with SSA
- continued
"C" Code Match Flag Comment Resolution no Mother = 5 29 no
Successful match to a deceased person’s record on the SSA database for mother.
If the mother’s identifiers are correct, the mother should contact SSA to fix their records.
Once SSA corrects its records, the mother can reenter the name and submit it as a SAR/ISIR correction for an updated match flag.
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Parent Social Security Number Match with SSA -
continued
"C" Code Match Flag Comment Resolution Reject 9 n/a 49 yes
Match w/ SSA was not conducted on either parent. One of SSN, last name and DOB is missing for
both parents. Must provide all appropriate data elements for
parents to enable the match w/ SSA. If parents do not have an SSN, provide zeroes
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Parent Social Security Number Match with SSA
- continued
"C" Code Match Flag Comment Resolution no n/a 166 no Father’s data not sent to SSA for data match. SSN for Father is not in SSA’s list of issued
SSNs. Father’s SSN appears to be invalid. Need to provide correct SSN for Father. If Father’s SSN is correct,Father should contact
SSA to ensure their records are correct.
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62
Parent Social Security Number Match with SSA
- continued
"C" Code Match Flag Comment Resolution no n/a 167 no
Mother’s data not sent to SSA for data match. SSN for Mother is not in SSA’s list of issued SSNs. Mother’s SSN appears to be invalid. Need to provide correct SSN for Mother. If Mother’s SSN is correct, Mother should contact
SSA to ensure their records are correct.
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63
Parent Social Security Number Match with SSA
- continued
"C" Code Match Flag Comment Resolution no n/a 48 no
Parent(s) SSN is the same as student’s SSN SSN for parent(s) is blanked out. Need to Correct parent(s) SSN.
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Parent Social Security Number Match with SSA
- continued
"C" Code Match Flag Comment Resolution no n/a 45 no
Parents’ marital status is not married. SSN provided for both Father and
Mother. Need to correct either parent marital status or
eliminate the appropriate parent SSN information.
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References
On IFAP (www.ifap.ed.gov)– SAR/ISIR Guide - Appendix B– Citizenship portion of FSA Handbook (Refer to
Volume 1, Chapter 2 (pp. 17-40))– Dear Colleague Letter GEN-05-16 (Q&A # 5)– Dear Colleague Letter GEN-06-09
IRS Website (www.irs.gov)– Pub. 17 (Your Federal Income Tax)– Pub. 513 (Tax Information for Visitors to the U.S.)– Pub. 519 (U.S. Tax Guide for Aliens)
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Contact InformationFor questions or to provide
feedback:Anthony Jones202-502-7652
Ginger Klock 202-377-3239