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Recent IRS CI Investigations Highlight Enforcement Priorities for 2021

Posted in Offshore Account Update on April 16, 2021 | Share

The Internal Revenue Service’s Criminal Investigation Division (IRS CI) has been extremely active in 2021. In March alone, IRS CI issued well over 100 press releases announcing new investigations. As Washington D.C. tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group, explains, IRS CI’s recent investigations provide some important insights into the division’s enforcement priorities for 2021.

PPP Loan Fraud and Other Forms of COVID-19-Related Tax Fraud

Several of IRS CI’s recent investigations have targeted individuals and businesses for fraudulently obtaining loans under the Paycheck Protection Program (PPP). IRS CI has also been targeting taxpayers for other COVID-19 tax fraud schemes. Many of these investigations have focused on taxpayers’ efforts to fraudulently obtain funds under relief programs other than the PPP, including the Economic Injury Disaster Loan (EIDL) program.

Failure to Disclose Offshore Accounts

Consistent with IRS CI’s enforcement priorities in recent years, the division has also initiated several investigations targeting U.S. taxpayers who have failed to disclose their offshore accounts—as required under the Bank Secrecy Act (BSA) and the Foreign Account Tax Compliance Act (FATCA). Notably, IRS CI is also targeting banks that are suspected of facilitating taxpayers’ efforts to conceal offshore accounts. For example, in March, IRS CI announced a deferred prosecution agreement with Swiss bank Rahn+Bodmer Co., which agreed to pay $22 million in fines for helping U.S. taxpayers hide their offshore accounts from the IRS.

Tax Preparer Fraud

IRS CI has recently pursued several cases against tax preparers who are accused of helping their clients file false returns and obtain fraudulent federal income tax refunds. The division announced 17 cases against tax preparers in March alone. While these cases vary in their specifics, they typically involve allegations of helping taxpayers fraudulently claim dependents, deductions, credits, exemptions and various forms of tax relief.

Investigations Targeting Foreign U.S. Taxpayers

While the majority of IRS CI’s investigations target U.S. residents, the division has also recently been pursuing a large number of cases against foreign U.S. taxpayers. IRS CI has recently announced investigations targeting taxpayers from or residing in Mexico, France, and Puerto Rico, among other countries and territories. International tax fraud is another top enforcement priority for IRS CI, and IRS CI works with its counterparts in countries around the world to investigate and prosecute cross-border tax fraud schemes.

General Tax Evasion

Of course, IRS CI still devotes a substantial portion of its resources to investigating general tax evasion and tax fraud. From individuals underreporting their taxable income to businesses fabricating expenses in order to take fraudulent deductions, IRS CI targets all types of taxpayers for all types of fraud—and in doing so it pursues charges for a broad range of statutory offenses.

Contact Washington D.C. Tax Attorney Kevin E. Thorn, Managing Partner of Thorn Law Group

If IRS CI is investigating you or your business, it is important that you engage experienced tax defense counsel immediately. To speak with Washington D.C. tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group, in confidence, call 202-349-4033, email ket@thornlawgroup.com or contact us online now.


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