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What does EIN reference number 104 mean?

EINIRS

Reference number 104 means the third-party designee's contact details overlap with the company's or the responsible party's, and the online tool treats that as a conflict. A designee is someone you authorize on the application to answer the IRS's questions about it and receive the number: a lawyer, an accountant or a formation service. The IRS's Form SS-4 instructions say that when the designee's address or phone number matches the taxpayer's, the application cannot go through online and must be faxed or mailed. The IRS has never said so in writing, but every account of 104 describes the same clash.

The common way to trigger it is a founder filling in the designee section for themselves, or for a co-founder, using the company's own address and phone. The designee is meant to be a separate person at a separate address, which is the whole reason the section exists.

The fix

If you are applying for your own company, leave the designee section empty and apply again. There is nothing a designee gives a founder who is sitting at the keyboard. If someone else is genuinely applying for you, they enter their own office address and phone number, not yours, and they need your signed authorization to do it. The designee's authority ends the moment the EIN is issued, so none of the company's later dealings with the IRS run through them.

Written by the lawyers who built Arabella. This is legal information, not legal advice for your situation, and reading it does not make us your lawyers. For a real dispute or a high-stakes decision, talk to a licensed attorney. More questions.