Unique Corporate Identifiers

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Laws and Regulations

From 1913 to 1976, income tax returns were classified as public records, and the President controlled access to the returns. In 1976 tax returns became confidential after concerns that the Nixon administration had improperly used tax return information against political opponents.

International Revenue Code Title 26, Subtitle F, Chapter 61, Subchapter B, Section 6103

  • IRS officials and others with access are prohibited from disclosing the information except under the limited exceptions delineated in the law.
  • Shareholders owning more than 1% of the outstanding stock of the corporation may inspect the corporation's return by making a written request to the IRS (noted, it is a felony for these shareholders to disclose any tax return information obtained from the IRS to anyone else)
  • Returns may be disclosed to certain government employees for tax administration purposes, ie. Department of the Treasury, Department of Justice
  • Disclosure permitted in nontax criminal investigations – a government attorney must submit an application to a federal judge
  • SEC lacks the ability to obtain taxpayer returns from the IRS, but will request the information directly from the taxpayers when relevant to a civil investigation
  • Notably, the fact that government regulators can already access tax return information when relevent in both tax and non-tax situations detracts from the argument for disclosure of corporate tax returns with the government

Internal Revenue Code Title 26, Subtitle F, Chapter 61, Subchapter B, Sec. 6109: Identifying Numbers

Employer identification numbers that are obtained or maintained pursuant to this subsection by the Secretary of Agriculture or the head of any agency or instrumentality with which information is shared pursuant to paragraph (2) shall be confidential, and no officer or employee of the United States who has or had access to the employer identification numbers shall disclose any such employer identification number obtained thereby in any manner. For purposes of this paragraph, the term “officer or employee” includes a former officer or employee.


Corporate Identification Methods

EIN Numbers

  • IRS resources
  • IRS Form 851 (Corporate Affiliations Schedule) (PDF)
  • Understanding your EIN from the IRS
  • 9 digits: XX-XXXXXXX
  • No new EIN needed if:
    • division of a corp
    • after a corp merger, surviving corp uses its existing EIN
    • corp declares bankruptcy
    • business name change
    • change or add location
    • corp reorganization
    • corp is sold
  • Sole proprietorships are not required to obtain EIN numbers; they may use the Social Security numbers of the proprietor for identification, if they wish
  • EIN are public record
    • SEC filings
    • Dept. of Labor
    • county or municipal business license office

Ways to search EINs

  • Melissa Data
    • 1.4 million registered nonprofits
    • name, assets, income, IRS subsection, deductibility status, classification, Form 990, contact information, type of foundation and organization
  • FEIN Search
    • 14 million EINs
    • have to pay
  • EIN Finder
    • have to pay
  • KnowX
    • LexisNexis company, have to pay
  • Free ERISA EIN Finder
    • Uses Dept. of Labor Form 5500 disclosure filings to get information
    • have to pay
    • over 7 million EINs
  • SEC Filings

EIN/TAX CODE In the News

Trading Partner Identification Number (TPIN)

  • confidential number assigned to organizations which are or intend to be contractors with the federal government, issued by the Central Contractor Registration (CCR) of the Dept. of Defense

FINDS Codes

  • Used by EPA. Facility-oriented. Can't find a good link.

CAGE Codes

  • unique identifier assigned to suppliers to various government or defense agencies, as well as to government agencies themselves and also various organizations. CAGE codes provide a standardized method of identifying a given facility at a specific location.
  • Used internationally as part of the NATO Codification System
  • Central Contractor Registration

DUNS – Data Universal Numbering System

  • Dun & Bradstreet
  • site specific – each distinct physical location of an entity (branches, divisions, headquarters, etc.) may be assigned a DUNS number (not the case with EIN)
  • different DUNS numbers for each legal division that may be co-located
  • required by Office of Management and Budget if your organization reports expenditures from direct federal awards; otherwise a DUNS number is requested but not required
  • replaced the Contractor Establishment Code (CEC) number previously used by the Federal Procurement Data Center for reporting on contractors doing business with the federal bulletin
  • DUNS info from Madnick, Wang, Xian
  • The DUNS family tree captures 8 types of entities:
    • single location subsidiary
    • headquarters
    • branch
    • division
    • subsidiary
    • parent
    • domestic ultimate
    • global ultimate
  • family tree captures two types of relationships
    • branch to headquarters
    • subsidiary to parent
  • each family member carries up to 4 DUNS numbers
    • it's own
    • the next highest family member
    • domestic ultimate
    • global ultimate
  • limitations
    • organization might not match companies' internal organizations
    • subsidiaries owned less than 50% by the parent company aren't listed

D&B Company Lookup search available

Interesting Tool


The Literature – Examining the Ecosystem

Creating a Linchpin for Financial Data: The Need for a Legal Entity Identifier - John A. Bottega, Federal Reserve Bank of New York and Linda F. Powell, Federal Reserve Board, 2010

Abstract:
The financial industry, like many others, is powered by information and data. A number of government agencies, quasi-government agencies, and private companies collect, process, use, and distribute information about a variety of players in the financial world. While the subjects of the data (balance sheet items or counterparty information, for example) may vary dramatically by agency and use, they all describe a particular financial institution or legal entity. Yet a standard way to uniquely identify one financial entity from another does not currently exist. A Social Security number distinguishes one John Smith from another John Smith, but at present no single identifier distinguishes one First National Bank from another. Several private companies have developed proprietary identifiers created for their own purposes but none of those identifiers are industry-wide, universal, or strictly focused on identifying a specific institution.

A diverse group of analysts from the Board of Governors of the Federal Reserve System, Federal Reserve Bank of New York, Commodity Futures Trading Commission (CFTC), Federal Deposit Insurance Corporation (FDIC), Financial Industry Regulatory Authority (FINRA), Securities and Exchange Commission (SEC), and Treasury have developed guidelines detailing the best way the industry might create, develop, and maintain such a crucial identifier. The paper summarizes the current environment of entity identification and the problems that are currently encountered in both the private and public sectors by the lack of an industry-wide identifier. The paper identifies the key components that should be incorporated into the LEI such as uniqueness, persistence, and public availability. The paper identifies possible alternative approaches to solving the LEI problem and supports a collaborative public and private sector approach. The paper also considers the need for an international solution, as financial markets grow ever more interconnected across the globe.

The Design and Implementation of a Corporate Householding Knowledge Processor to Improve Data Quality - Madnick, Wang, Xian


This 2004 article from the Journal of Management Information Systems discusses how improvements in corporate householding data collection are essential to addressing data quality problems that result from data misinterpretation. The article explains how the business environment changes quickly and creates a complex business environment that is hard to decipher.

Definitions:

  • Corporate Household: a group of business units united or regarded united with the corporation such as suppliers and customers whose relationships with the corporation must be captured, managed, and applied for various purposes.
  • Corporate Household Knowledge: the actionable knowledge about organizations and related internal and external relationships
  • Corporate Householding: the process of capturing, analyzing, understanding, and managing corporate household knowledge
  • Categories of Corporate Householding problems:

1.Entity Identification
2.Entity Aggregation
3.Transparency of Inter-entity relationships

  • Corporate Householding Application Areas:

1.Account consolidation and financial risks
2.Legal sector concerns
3.Business management and operations

E-File, Enterprise Structures, and Tax Compliance Risk Assessment - Boynton, Lisowsky, Trautman


This 2008 article from TAX NOTES discusses how the electronic filing of corporate and partnership tax returns in XML format allows for companies to be viewed in a comprehensive way rather than just as a tax return filing entity. It is possible to access all tax return information immediately after they have been filed and to use open source XML and object-oriented programming technologies to combine tax return information with financial statement information and information on similar entities into an “enterprise data structure” that shows the organizational structure of the enterprise.


Book-Tax Consolidation, Rates of Return, and Capital Structure - Lisowsky, Trautman


A 2003 study looked at discrepancies in financial reporting – found a positive relationship at the firm level between differences in the rates of return reported for the financial and tax consolidated groups and differences in tax return and financial statement capital structure measures

Public Disclosure of Corporate Tax Return Information: Accounting, Economics, and Legal Perspectives - Lenter, Shackelford, Slemrod

Bush Administration resisted attempts to legislate against corporate abuses, but Congress has passed legislation aimed at stopping and punishing corporate fraud.


In 2002 Sen. Grassley asked the SEC and Treasury if it might be beneficial to publicly release corporate tax returns. Both entities rejected the proposal – SEC said benefits would be “marginal at best” while the Treasury said that the complexity of the tax returns would confuse the public and lead to misinformed analysis

Different possibilities for extent of disclosure:

  • Making tax returns public in their entirety
  • make only certain portions public
  • disclose only the bottom line tax liability of each corporation
  • disclose the Schedule M-1 (or a summary version) – the tax return schedule that reconciles taxable income with the accounting earnings computed for financial reporting purposes
  • improve the tax reporting on a company's financial statements either through voluntary disclosure by firms or mandate by the Financial Accounting Standards Boardd (FASB) or the SEC
  • make taxable income more closely conform to accounting income


History

  • starting in 1976 the IRS was not longer allowed to disclose tax returns to other government regulators
  • 1861 was the first federal income tax – wording of the Revenue Act suggested that the tax assessment information was public
  • 1862 Act allowed public to see the names of taxpayers and the amounts of their tax liabilities – tax assessors compiled lists which were posted in public places
  • 1864 tax lists still public, newspapers started publishing the lists
  • 1870 assessors barred from providing tax lists for publication, Congress prohibited publication of all or any part of an income tax return
  • 1894 new income tax passed – Congress specifically prohibited government officials from making any part of the tax return public
  • Corporate Excise Tax of 1909 (precursor to current corporation income tax) – President Taft believed that by taxing corporations and making returns public, the government would provide the public and regulators with the ability to learn details about the business transactions and profits of corporations – step toward regulation. At that time disclosing corporate tax return information would be the “most consistent and comprehensive source of corporate information.”
  • 1910, Commissioner of Internal Revenue ruled that Congress hadn't specifically appropriated money for public inspection of tax returns and thus the returns would be confidential
  • Congress appropriated money for classifying, indexing, and exhibiting tax returns, but made a provision that returns could only be inspected by order of the President or under rules established by the Treasury and approved by the President
  • President Taft Executive Order established two ways to gain access to tax returns:
  • Shareholders could apply for permission to inspect the tax returns by describing the reason for the inspection
  • Everyone was allowed to inspect returns if the corporation's stock was listed on a public exchange or advertised in the press or offered for public sale
  • However, returns could only be inspected at the office of the Commissioner of Internal Revenue
  • 1924 Revenue Act made public disclosure the rule for individual and corporate taxpayers – not the returns but the names and tax payments
  • 1926 – only names and addresses of taxpayers were public, not their tax liabilities
  • 1934 discovery of tax fraud → publicity provisions included in Revenue Act – pink slips – carbon copies of tax return with only some of the information on it repealed under President Roosevelt – no federal disclosure provision has been implemented since
  • Disclosure of tax data remained under the discretion of the Executive Branch until Nixon. His use of IRS data to bully opponents led to additional privacy restrictions.


Often at the state level tax returns have been made public documents open for review

  • Arkansas, Massachusetts, West Virginia, and Wisconsin provide some public disclosure of state income tax information
  • Secretary of State required to maintain those reports and make them available for public inspection on request, but the names and addresses of the companies are removed


Of the OECD countries, only Japan, Norway, Sweden, and Finland allow public access to information in corporate tax returns

In other contexts...

  • Form 990-T (nonprofit income tax return) is not publicly available but Form 990 (filled out by all tax-exempt organizations except Federal agencies, religious bodies, private foundations, and low grossing organizations) is publicly available.


Arguments For Disclosure (Lenter, Shackelford, Slemrod):


  1. improve government regulation of corporations (idea being that corporations need to be better policed and that the information currently available to government regulators is insufficient)
  2. help the financial markets function more effectively by improving financial report qualit
  3. possibility that companies could submit misleading financial reports because the public as well as the SEC does not have access to outside information to compare it to
  4. increase compliance with tax laws and facilitate tax law enforcement
  5. increase public pressure for good tax policy


Arguments Against Disclosure (Lenter, Shackelford, Slemrod):


  1. disclosure of tax returns would be useless and confusing
  2. violate a central tenet of tax law: confidentiality of tax returns, and cause companies to disclose less on their returns
  3. reveal valuable and private business information to competitors (loss of proprietary information)
  4. violate 4th and 5th Amendments
  5. Supreme Court dismissed Fourth Amendment challenges in Flint v. Stone Tracy Co.
  6. Supreme Court also dismissed Fifth Amendment challenges in U.S. vs. Sullivan and Garner v. United States
  7. increasing government access to tax return information gives federal bureaucracy too much power over taxpayers


Possible Compromises (Lenter, Shackelford, Slemrod)


  1. disclose only a part of the return (ex. The first four pages of the Form 1120)
  2. expand the Schedule M-1 to the corporate tax return and make it public
  3. Kleinbard and Canellos proposal (2003): create a single public financial statement using a publicly held corporation's Schedules M and L and its financial statement income tax disclosure. This document would be filed with the corporation's tax return instead of the existing Schedule M and also included in the corporation's financial statements
  4. Mills and Plesko proposal (2003): a Schedule M-1 that requires companies to file consolidated tax returns and provide the information necessary to link the returns to the financial reports of the related consolidated financial reporting entities
  5. make book accounting correlate more closely with tax accounting


Other Interested Parties

  • MIT Total Data Quality Management Program
    • research data quality and accuracy with the goal of better understanding and utilizing corporate household data
  • First Logic Inc.
    • uses Subject Matter Experts (SME) approach to identify entities correctly and efficiently and build useful hierarchical structures
  • Dun and Bradstreet
    • developed DUN numbers as a representation of corporate structure
  • Securities and Exchange Commission (SEC)
  • Treasury Department
  • Financial Accounting Standards Board (FASB)
  • Tax Executives Institute (TEI)
    • an organization of business executives who are responsible for tax matters
    • feel that disclosure of corporate tax returns is not a well-targeted solution to the problem of facilitating SEC regulating activities
  • Senator Grassley
    • In 2002 asked the SEC and Treasury if it might be beneficial to publicly release corporate tax returns. Both entities rejected the proposal – SEC said benefits would be “marginal at best” while the Treasury said that the complexity of the tax returns would confuse the public and lead to misinformed analysis
    • Find the text of his letters here
  • Corporate Citizen Watch
  • House and Senate Taxation Committees
  • The Brookings Institution


Government Methods of Unique Identification

Superintendent of Documents Classification System

This is a brief overview of the Superintendent of Documents Classification System based on this Federal Depository Library Explanation.  This classification system was developed by the Library of the Government Printing Office between 1895 and 1903.  It was first used to assign classification numbers to Department of Agriculture publications based on government organization authorship.  The system expanded with the expansion of the federal government.  Each Executive department and agency, the Judiciary, Congress, and other independent entities are assigned a unique alphabetical identifier.  Subordinate bureaus and offices are identified by adding a number after the alphabetical identifier.  The main problem with this system is that it is based on the current organizational status of the government so it changes slightly whenever government organization changes.  This can result in documents being located in multiple places, but the problem has not prevented this system from being widely used.

More Resources:

Federal Information Processing Standard (FIPS)


This brief summary of FIPS is drawn from the U.S. Census Bureau.


Federal information processing standards codes (FIPS codes) are a standardized set of numeric or alphabetic codes issued by the National Institute of Standards and Technology (NIST) to ensure uniform identification of geographic entities through all federal government agencies. The entities covered include: states and statistically equivalent entities, counties and statistically equivalent entities, named populated and related location entities (such as, places and county subdivisions), and American Indian and Alaska Native areas.

More resources:

American National Standards Institute (ANSI) Codes

This brief summary of ANSI is drawn from the U.S. Census Bureau.


American National Standards Institute codes (ANSI codes) are a standardized set of numeric or alphabetic codes issued by the American National Standards Institute (ANSI) to ensure uniform identification of geographic entities through all federal government agencies. These standards replace the Federal Information Processing Standards (FIPS) codes previously issued by the National Institute of Standards and Technology (NIST). The entities covered include: states and statistically equivalent entities, counties and statistically equivalent entities, named populated and related location entities (such as, places and county subdivisions), and American Indian and Alaska Native areas.

More Resources:

Federal Procurement Data System (FPDS) / Procurement Instrument Identifier (PIID)

This brief summary comes from the 1998 FPDS Product and Service Codes Manual.


Public Law 93-400 requires the Administrator for Federal Procurement Policy, OMB, to establish a system for collecting, developing, and disseminating procurement data which takes into account the needs of the Congress, the executive branch, and the private sector. The Department of Defense was designated as the executive agent of the Office of Federal Procurement Policy to establish and operate the Federal Procurement Data System (FPDS) including a Federal Procurement Data Center. In April 1980, this responsibility was transferred to the General Services Administration.

PIIDs are a unique number, in most cases the contract number, given to a procurement document.

More Resources:


Other Sources of Identifier Info

UPC database(s)

Patent & TM office registry of companies

State-level corporate registries (typically gated)


Miscellaneous Notes on Disambiguation

Signals that are useful for company disambiguation: name, geo, hierarchy (if poss), jurisdiction, time of record, relative sizes of universes to be matches against one another (if possible -- e.g. is A a subset of B, or will matching A against B necessitate the creation of new records in B?)

Time resolution can be a problem -- 1 yr resolution means that if a sale occurred during a calendar year, two different companies might be shown to own one division/property simultaneously

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