Taxpayer Identification Numbers / Data Practices Office

Taxpayer Identification Numbers

Taxpayer identification numbers (Taxpayer ID numbers) generally include Social Security numbers (SSNs), State Taxpayer Identifying numbers (State Tax ID numbers), and Federal Employer Identification numbers (FEIN). The classification of this data depends on the type of Taxpayer ID number and which government entity maintains the data. Taxpayer ID numbers are classified differently when maintained by the Minnesota Department of Revenue than when they are maintained by other government entities. Please see the sections below for information on the how Taxpayer ID numbers are classified when maintained by the Department of Revenue or by other government entities. Alternatively, this information is available in to view in chart format.

At the Department of Revenue:

Social Security Numbers (SSNs)
State Taxpayer Identifying Numbers (State Tax ID numbers)
Federal Employer Identification Numbers (FEIN)

When the Department of Revenue receives FEINs from the IRS, disclosure is prohibited by federal law under 26 U.S.C. § 6103(a). When the Department of Revenue receives FEINs from other sources – FEINs are classified as private/nonpublic data under Minnesota Statutes, section 270B.02. However, certain disclosures are authorized under Minnesota Statutes, section 270B.12 (for tax law administration) and Minnesota Statutes, section 270B.14 (for non-tax purposes).

At other government entities:

Social Security Numbers (SSNs)
SSNs are classified as private data except when they appear in documents or records filed or recorded with the county recorder or registrar of titles, other than documents filed under Minnesota Statutes, section 600.23 (Minnesota Statutes, section 13.355). County recorders/registrars should consult the specific statutes applicable to them to determine the classification of SSNs they maintain.

Even though SSNs are generally private data, many sections within Chapter 13 authorize certain disclosures of SSNs. For example:
- Minnesota Statutes, section 13.69 authorizes sharing of SSNs in driver’s license & motor vehicle registration records for limited purposes with the Department of Revenue, the Department of Labor and Industry, the judicial branch, the Department of Natural Resources, and the Department of Human Services.
- Minnesota Statutes, section 13.585, subd. 6 authorizes public housing agencies to share SSNs with law enforcement under certain circumstances.
- Minnesota Statutes, section 13.46, subd. 2 authorizes the welfare system to disclose SSNs to the Department of Revenue, and federal and state law enforcement under certain circumstances.
- Minnesota Statutes, section 13.32, subd. 3 authorizes disclosure of SSNs of certain adult students to Minnesota State Colleges and Universities and DEED.
Further, additional sharing is authorized in other chapters. For example, Minnesota Statutes, section 97A.482 authorizes disclosures of SSNs on fish & game license applications to the commissioner of children, youth, and families for child support enforcement purposes. Similarly, Minnesota Statutes, section 144.215, subd. 4 authorizes the Office of Vital Records to provide parents’ SSNs to the public authority responsible for child support services for use in the establishment of parentage and the enforcement of child support.
State Taxpayer Identifying Numbers (State Tax ID numbers)

State Tax ID numbers are classified as public data (Minnesota Statutes, Section 13.01, subd. 3). State Tax ID numbers are not specifically classified by chapter 13, so the general public presumption for government data applies.

However, Minnesota Statutes, section 13.591 classifies income tax returns submitted to a government entity by a business requesting financial assistance or a benefit financed by public funds as private/nonpublic data. Similarly, Minnesota Statutes, section 13.204, classifies tax returns submitted to a political subdivision by a person seeking to obtain a license as private/nonpublic data. So, if a State Tax ID number is included in a tax return submitted for one of these purposes, the State Tax ID number would be classified as private/nonpublic.
Federal Employer Identification Numbers (FEINs)

When a government entity receives FEINs from the IRS, disclosure is prohibited by federal law under 26 U.S.C. § 6103(a).

When a government entity receives FEINs from other sources – FEINs are classified as public data (Minnesota Statutes, section 13.01, subd. 3). FEINs are not specifically classified by Chapter 13, so the general public presumption for government data applies.

However, Minnesota Statutes, section 13.591 classifies income tax returns submitted to a government entity by a business requesting financial assistance or a benefit financed by public funds as private/nonpublic data. Similarly, Minnesota Statutes, section 13.204, classifies tax returns submitted to a political subdivision by a person seeking to obtain a license as private/nonpublic data. So, if an FEIN is included in a tax return submitted for one of these purposes, the FEIN would be classified as private/nonpublic.

Additionally, under Minnesota Statutes, section 272.115, subd. 1, FEINs that appear in real estate certificates of value are classified as private/nonpublic data, but disclosure to the Commissioner of Revenue for tax administration purposes is authorized.