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Third Party Disclosure and Interactions – IIT
Disclosure and Interactions
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Third Party Permissions
Third parties include tax professionals, service providers, non-liable family members, and friends. When a third party is communicating with Treasury about account-specific matters, the taxpayer must provide consent.
Check the Box and Power of Attorney (POA) authorizations are currently used exclusively for receiving direct communication from Treasury without the taxpayer's direct involvement or presence (e.g., phone calls, emails, in person meetings, and web messages).
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Direct Interactions (e.g., in-person meetings, phone calls, email, web messaging, etc.)
Verbal Interactions
During a meeting or phone call where both the taxpayer and third party are present, the taxpayer can give Treasury permission to disclose information to the third party on a one-time basis. However, this authorization is temporary and expires when the interaction ends.
Check the Box
Taxpayers may authorize Treasury to discuss a specific tax return with the tax preparer identified on the return by marking the designated preparer authorization checkbox. This authorization is limited to matters related to the processing of that return, including refund and payment status and related correspondence, but is effective in the third party receiving direct communication from Treasury without the taxpayer's direct involvement or presence.
Power of Attorney (POA)
A Form 151, Authorized Representative Declaration/Power of Attorney is required for matters outside the scope of the preparer checkbox including audit, assessment, collection, appeals, or broader representation before Treasury. This authorization is specific to matters outlined on the form but is effective in the third party receiving direct communication from Treasury without the taxpayer's direct involvement or presence.
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Indirect Interactions: Web Platform Access
Portals
- Taxpayers use the MiTreasury eServices - Citizen Portal to access their own tax information.
- Check the Box and POA authorizations are not required for a third party to use Michigan Treasury eServices and do not impact access to taxpayer information online.
- All professional third parties (e.g., tax professionals and service providers) use the MiTreasury eServices - Business Portal to access client information.
- All personal third parties (e.g., a taxpayer’s friend or family member helping out) use the MiTreasury eServices – Citizen Portal to access taxpayer information.
Level Independent Permissions for Third Parties
Many functions through Michigan Treasury eServices do not require specific permission for third parties to view or send tax information.
Level 1: Guest Services
- Check return and refund status, make a payment, respond to letters (with supporting documents)
- No log in or connection to client account
Level 2: Logged In Services
- Send secure web messages (if check the box/POA authorizations in place, Treasury can provide detailed responses)
- Must log in using your professional, personal MiLogin for Business user profile
Level Dependent Permissions for Third Parties
Some functions through Michigan Treasury eServices require specific permission to view and send protected tax account information including access to file all tax returns, viewing estimated payments, viewing and amending filed returns, and viewing Treasury-issued letters.
Level 3: Connected Services
- All processing, filing, payment details
- Established when a connection is made between a user profile and the tax account. Taxpayers should review the Connect to Your Tax Account guide to reach Level 3 access.
- To reach Level 3 access, third parties must:
- Log in to the appropriate Portal and send an electronic request to access to the client’s individual income tax account. This process involves answering shared secret questions.
- Be approved by the taxpayer. The taxpayer must respond to the access request electronically. To receive the request, the taxpayer must be logged in and connected to their own tax account through the MiTreasury eServices - Citizen Portal. To make the connection, the taxpayer must validate their user profile using an accepted form of identification a camera enabled device. For step-by-step guidance on this taxpayer connection process, review the Connect Your Tax Account tutorial.
POA and check the box authorizations do not bypass this connection process.
Treasury has received feedback from tax professionals about third-party interactions and disclosure. We are actively exploring POA/check the box integration into Michigan Treasury eServices and are committed to improving POA/check the box processing and portability across Treasury work areas.