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IRS CI Highlights “Emphasis Areas” for Tax Enforcement in 2022

Offshore Account Update

Posted on May 20, 2022 |

The Internal Revenue Service’s Criminal Investigation Division (IRS CI) is extremely busy. It initiates well over 1,000 investigations annually, and it routinely issues press releases touting the results of these efforts in the form of criminal charges, guilty pleas and convictions.

When conducting its law enforcement efforts, IRS CI focuses its resources on several key areas. In this article, Boston tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group, discusses some of IRS CI’s “emphasis areas” for 2022.

IRS CI is Prioritizing Enforcement in These Areas in 2022

IRS CI maintains an updated list of program and emphasis areas on its website. For 2022, some of the most notable areas for U.S. taxpayers include the following:

Abusive Tax Schemes

Abusive tax schemes involve efforts to shield income and assets from U.S. federal tax liability. This includes the use of domestic and foreign trusts, offshore bank accounts, and other means of tax avoidance. While none of these are inherently illegal, IRS CI is well aware that taxpayers frequently use contrived structures to evade their federal income tax liability.

Corporate Fraud

Combating corporate tax fraud has long been a top IRS CI enforcement priority, and this is unlikely to change anytime soon. IRS CI targets companies for a broad range of tax law violations, from underreporting their taxable income to inflating their payroll and other expenses.

Employment Tax Enforcement

IRS CI targets companies for a variety of types of employment tax fraud. This includes (but is not limited to) “pyramiding, employee leasing, paying employees in cash, [and] filing false payroll tax returns.”


As gambling grows in popularity due to the availability of phone apps and online platforms, IRS CI is cracking down on gaming-related income tax compliance. The division is targeting individuals who fail to report their gambling income as well as companies that fail to maintain strict federal tax compliance.

General Tax Fraud

While focusing on various specific tax law violations, IRS CI continues to prioritize general tax fraud as well. This includes targeting taxpayers, “who chose to willfully and intentionally not comply with their legal responsibility to file required tax returns and/or pay taxes.”

International Tax Fraud

Fighting international tax fraud is another longstanding IRS CI enforcement priority. Along with targeting abusive tax schemes, IRS CI is also focusing on ensuring compliance with U.S. taxpayers’ FATCA and FBAR filing requirements.  

Money Laundering and Bank Secrecy Act (BSA) Violations

In many cases, IRS CI works alongside other federal law enforcement agencies and international tax authorities to conduct large-scale takedowns. This is particularly common in cases involving allegations of money laundering and Bank Secrecy Act (BSA) violations. Individuals targeted in these takedowns will often face multiple criminal charges, substantial fines, and years or decades of federal imprisonment.

Request a Consultation with Boston Tax Attorney Kevin E. Thorn

Boston tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group, has extensive experience representing individuals and corporations during IRS CI investigations. If you need experienced legal representation for a federal tax case, call 617-692-2989, email ket@thornlawgroup.com or contact us online to arrange a confidential consultation.

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