• Part 9. Criminal Investigation • Chapter 5. Investigate Process • Section 3. Criminal Investigation Strategies
Tax crimes are those which are in violation of the criminal statutes of Title 26, Title 18 and/or Title 31 of the Code of Federal Regulations as applicable to Title 26. Although violations of narcotics, money laundering or currency statutes usually have tax ramifications, those types of violations, will be discussed in separate sections.
Criminal Investigation strategies consist of Compliance, Money Laundering, International and Terrorism. The Annual Business Plan (ABP) issued each fiscal year by the Chief, Criminal Investigation (CI), provides specific direction relative to the major strategies and operational priorities. The ABP also attempts to identify emerging areas of non-compliance, so that resources can be redirected, if required. Timely identification and intervention often prevents "emerging areas" from becoming more serious compliance problems. This section addresses the various programs and initiatives and selectively describes some of the fraud schemes routinely encountered.
Also introduced in this section are the Money Laundering and Terrorism strategies.
Criminal Investigationís strategies are classified in terms of:
priorities within the program areas
initiatives in which CI participates
schemes encountered in the program areas
other situations to which the special agent should be sensitive when conducting an investigation
188.8.131.52 Compliance Strategy
Criminal Investigationís Compliance strategy is comprised of the following programs:
Legal Source Income
Illegal Source Income
CI is the sole investigating agency
Within the legal source income program are the following initiatives, which are all part of the overall IRS Strategic and Program Plan or an ongoing commitment by the IRS:
Income Tax - investigations relating to income from businesses, investments, or other legal activities and industries
Employment Tax - investigations relating to unreported, underreported, unpaid, or underpaid employment tax obligations
Excise Tax - investigations involving violations of the excise tax laws
Abusive Tax Schemes - investigations involving abusive and/or fraudulent schemes to evade taxes which encompass violations of the Title 26 and related statutes where multiple flow-through entities are used as an integral part of the schemes. Such schemes are characterized by the use of trusts, Limited Liability Companies (LLCs), Limited Liability Partnerships (LLPs), International Business Companies (IBCs), foreign financial accounts, offshore credit/debit cards, and other similar instruments.
Gaming - investigations relating to the income generated from the legal gaming industry
Questionable Refunds (QRP) - investigations involving fraudulent tax refund schemes
Unscrupulous Return Preparers (RPP) - investigations involving preparers of false and/or fraudulent tax returns
Frivolous Filer/Non-filers - investigations involving the most egregious non-filers
The CI Annual memorandum determines the investigatory emphasis on these priorities.