means of reidentification be prevented with any public release of data. All FTI, including the building blocks of any list frame, such as name, address, and TIN, will probably remain subject to perpetual protection under provisions of the tax code, as discussed previously. Accordingly, legislators who understand that the statistical community has the issue of taxpayer and respondent confidentiality foremost in mind as it seeks expanded access to confidential data may be more sympathetic to a future J bill. Demonstrating such care and foresight may also assist with any future proposals that might expand data sharing beyond three agencies and encompass more than business data.


We view FTI as a national asset that can have great value in many situations faced by the statistical community. However, this asset comes with numerous constraints on its use, in particular, a strong emphasis on taxpayer confidentiality and a requirement that only the minimum amount of FTI be provided to meet authorized uses. These constraints can be productively addressed through good faith bargaining between the IRS and the statistical agencies authorized to receive FTI. We believe this bargaining process is a useful way to strike the right balance between needed access to FTI and concerns for taxpayer confidentiality. Future expansions of the statutory provisions allowing access to FTI are possible, but will take a concerted effort by the affected federal statistical agencies. Learning from past efforts can help increase the chances of success in this endeavor.

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