Criminal investigations at IRS are handled by the Criminal Investigation Division (CI) that operates through approximately 2,600 special agents. Cases investigated by CI are reviewed by attorneys with the IRS Chief Counsel Office and then forwarded to the Department of Justice for further review and prosecution. CI is the gateway for the IRS offshore voluntary disclosure program that offers qualifying taxpayers the ability to apply for a voluntary disclosure with the IRS and to settle their cases without criminal prosecution. Activity in this area has increased greatly with dramatic IRS success in getting through foreign bank secrecy.
Practical next steps
- Note the date on this article. It describes the rules as they stood then, and tax procedure changes.
- Start from the notice you actually received: the number in the top right corner and the date printed on it decide what is still open to you.
- Pull your account transcripts before deciding anything. They show what the IRS believes about your account, which is not always what the letters say.
- If a deadline is running or the amount is significant, have someone read the file before you respond.
Official sources for current verification
- IRS Criminal Investigation
- IRS Manual — Criminal Investigation Strategies
- IRS Manual — Recognizing and Developing Fraud
- IRS Criminal Investigation Voluntary Disclosure Practice
- IRS — Options for Undisclosed Foreign Financial Assets
- IRS — Streamlined Filing Compliance Procedures
Important notice
This material provides general information, not legal or tax advice. Tax outcomes depend on the facts, procedural history, applicable law, and current agency guidance. Reading this page does not create an attorney-client relationship.
