Original Date Announced

The Washington Post reports that DHS asked the IRS to divulge the last-known home addresses, phone numbers, and email addresses of 700,000 potentially undocumented immigrants. DHS also asked the IRS to deploy auditors and criminal investigators to launch probes of businesses suspected of hiring immigrants not authorized to work. The memo follows a prior DHS request to allow immigration officials to provide names and obtain home addresses. IRS leadership initially refused DHS's requests; however, a new acting IRS commissioner has since taken over and indicated interest in compliance.

Trump 2.0 [ID #1583]

Subsequent Trump and Court Action

2025.03.07 Complaint - Centro de Trabajadores Unidos v. Bessent

Centro de Trabajadores Unidos and Immigrant Solidarity DuPage, two Illinois-based immigrant advocacy organizations, filed a complaint seeking declaratory and injunctive relief against the Treasury and the IRS for alleged violations of Internal Revenue Code § 6103(a) for attempting to share taxpayer data with DHS and ICE. Centro de Trabajadores Unidos v. Bessent, No. 1:25-cv-00677 (D.D.C.).

**Link to case here. Our litigation entries generally report only the initial complaint and any major substantive filings or decisions. For additional information, CourtListener provides access to PACER and all available pleadings. Other sites that track litigation in more detail or organize cases by topic include Civil Rights Clearinghouse, Justice Action Center, National Immigration Litigation Alliance, and Just Security**

Subsequent Trump and Court Action

2025.03.20 Order Denying TRO - Centro de Trabajadores Unidos v. Bessent

District Judge Dabney Friedrich denied the plaintiffs' motion for a temporary restraining order, citing failure to demonstrate standing. The Court stated that "[a] single news report about future cooperation between the IRS and DHS does not establish that the plaintiffs’ members are facing imminent injury," especially "where the government has represented to the Court that it is abiding by the law." Centro de Trabajadores Unidos v. Bessent, No. 1:25-cv-00677 (D.D.C.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.03.22 Reported: IRS nears deal with ICE to share addresses of suspected undocumented immigrants - Washington Post

The Washington Post reported that the IRS is nearing an agreement with DHS. Under the agreement, ICE would be able to submit names and addresses of suspected undocumented immigrants to the IRS to cross-reference with confidential taxpayer databases.

Subsequent Trump and Court Action

2025.03.26 Amended Complaint - Centro de Trabajadores Unidos v. Bessent

Plaintiffs filed an amended complaint for declaratory and injunctive relief. The new complaint adds DHS, DHS Secretary Kristi Noem, ICE, and ICE Acting Director Todd Lyons as defendants. The amended complaint asserts that DHS Defendants "seek confirmation of address information for the purpose of locating targets for civil removal" which is not authorized under 26 U.S.C. § 6103(i)(2). They also argue that harm to the Plaintiffs is imminent because "[o]nce the agreement [between Treasury Defendants and DHS Defendants] is finalized, the IRS will begin sharing taxpayer information on a mass scale with DHS Defendants . . . [and] it will be virtually impossible to undo the harm through an order limiting its use or further dissemination." Centro de Trabajadores Unidos v. Bessent, No. 1:25-cv-00677 (D.D.C.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.04.05 Reported: DHS officials ask IRS to use tax data to locate up to 7 million immigrants - Washington Post

The Washington Post reports that although "[t]he two agencies have still not reached an agreement on how much data or how the IRS would share it," DHS expanded its request for taxpayer data from 700,000 immigrants with final orders of removal to "up to 7 million people suspected of being in the United States unlawfully." According to the Post, "IRS executives told Homeland Security officials that their request likely violates the narrow criminal investigation exemptions" to federal privacy laws regarding taxpayer data.

Subsequent Trump and Court Action

2025.04.07 ICE and IRS - Memorandum of Understanding

ICE and the IRS entered into a Memorandum of Understanding that creates a framework for information-sharing between the agencies. The MOU permits ICE to obtain taxpayer information from the IRS for individuals with final removal orders who are under federal criminal investigation.

The MOU was disclosed during litigation in Centro de Trabajadores Unidos v. Bessent, 1:25-cv-00677 (D.D.C.).

Subsequent Trump and Court Action

2025.04.08 Reported: Top I.R.S. Officials Said to Resign After Deal to Give ICE Migrants’ Data - New York Times

The New York Times reports several top IRS officials, including the acting commissioner, Melanie Krause, will resign in response to the new MOU between the IRS and ICE.

Subsequent Trump and Court Action

2025.04.25 Reported: Inspector General Probes Whether Trump, DOGE Sought Private Taxpayer Information or Sensitive IRS Material - ProPublica

ProPublica reports that the Office of the Treasury Inspector General for Tax Administration has launched a probe into "efforts by President Donald Trump and Elon Musk's Department of Government Efficiency to obtain private taxpayer data and other sensitive information." The office sent an email in mid-April seeking a "swath of information from IRS employees," including "any requests for taxpayer data from the president, DOGE or the president's Office of Management and Budget."

Subsequent Trump and Court Action

2025.05.12 Order Denying Preliminary Injunction - Centro de Trabajadores Unidos v. Bessent

Judge Dabney Friedrich denied the motion for a preliminary injunction. He held that the Memorandum of Understanding between the IRS and DHS discussed in this policy entry does not violate the Internal Revenue Code. He explained that "the plain language of 26 U.S.C. § 6103(i)(2) mandates disclosure under the specific circumstances and preconditions outlined in the Memorandum." Based on the limited record, "the Court cannot assume that DHS intends to use the shared information to facilitate civil rather than criminal proceedings." Centro de Trabajadores Unidos v. Bessent, No. 1:25-cv-00677 (D.D.C.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.05.16 Amended Complaint - Center for Taxpayer Rights v. IRS

The Center for Taxpayer Rights, Main Street Alliance, the National Federation of Federal Employees, and Communications Workers of America filed a complaint against the Trump administration to challenge its inter-agency data-sharing practices. The complaint alleges that the Department of Government Efficiency (DOGE) has sought and obtained confidential taxpayer information from the IRS, and has further influenced IRS decision-making to enable broad sharing of taxpayer data with DHS as well for immigration enforcement. Plaintiffs allege that the disclosures violate the Tax Reform Act, Privacy Act, and Administrative Procedure Act. Center for Taxpayer Rights v. International Revenue Service, No. 1:25-cv-00457 (D.D.C.).

**Link to case here. Our litigation entries generally report only the initial complaint and any major substantive filings or decisions. For additional information, CourtListener provides access to PACER and all available pleadings. Other sites that track litigation in more detail or organize cases by topic include Civil Rights Clearinghouse, Justice Action Center, National Immigration Litigation Alliance, and Just Security**

Subsequent Trump and Court Action

2025.07.15 Reported: The IRS Is Building a Vast System to Share Millions of Taxpayers’ Data With ICE - ProPublica

ProPublica reports that the IRS is building a computer program that would give deportation officers “unprecedented access to confidential tax data.” The system would grant ICE automated access to home addresses en mass, limiting the ability of IRS officials to consider the legality of transfers. The goal is to launch the new system before the end of July. White House and DHS officials have cited the April MOU and the District Court for the District of Columbia's approval of the MOU as authorization for the new system.

Subsequent Trump and Court Action

2025.08.08 Reported: IRS begins sharing sensitive taxpayer data with immigration authorities to find undocumented migrants - CNN

CNN reports that the IRS has begun sharing taxpayer data with immigration authorities to help locate undocumented migrants. The data include names, addresses, and tax information for individuals facing deportation or criminal investigations. ICE requested information for 1.23 million people, but less than 5% of the records were shared due to data mismatches.

Subsequent Trump and Court Action

2025.09.09 Minute Orders - Center for Taxpayers Rights v. IRS

U.S. District Judge Kollar-Kotelly ordered the IRS to notify the court within 24 hours of receiving a request for information from DHS or ICE. The court also ordered production of the administrative record underlying IRS's decisions to share data with immigration authorities. Center for Taxpayer Rights v. Internal Revenue Service, No. 1:25-cv-00457 (D.D.C.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.09.30 Complaint - CEDC v. Bessent

Four community organizations filed suit against the administration to challenge data-sharing agreements and practices between the SSA and ICE, and between the IRS and ICE. The complaint alleges that ICE has already received more than 43,000 physical addresses and uploaded those addresses to the agency’s broadly accessible databases. Plaintiffs allege that the “unfettered interagency data-sharing” violates the Tax Reform Act, Administrative Procedure Act, and First Amendment, and chills tax filing by immigrants who fear exposing themselves and family members to arrest, detention, and removal. Cmty. Econ. Dev. Ctr. of SE Mass. v. Bessent, No. 25-cv-12822 (D. Mass.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2025.10.30 Reported: ICE made expansive request for taxpayer data amid IRS pushback - Politico

Politico reports that the IRS administrative record in Center for Taxpayer Rights v. Internal Revenue Service, No. 1:25-cv-00457 (D.D.C.), reveals that ICE asked the IRS to provide all possible information on "700 thousand criminal illegal aliens who have standing deportation orders.” The request included known home addresses, employers’ information, relatives, bank names, IP information, and Social Security or taxpayer-identification numbers. The records show that the IRS reviewed the information exchange's legality and practicality.

The administrative record is available here, at Docket No. 48.

Subsequent Trump and Court Action

2025.11.21 Order Granting Stay - Center for Taxpayer Rights v. International Revenue Service

Judge Kollar-Kotelly issued an order staying the IRS policy authorizing disclosure of taxpayers' confidential address information to ICE. Judge Kollar-Kotelly found a "substantial likelihood" that the address-sharing policy and subsequent disclosure of tens of thousands of addresses to ICE violated the Administrative Procedure Act (APA) and federal tax law. The order enjoins unlawful data-transfers from the IRS to DHS and requires the IRS to notify the court and Plaintiffs before making "any transfers that the IRS believes are lawful."

The order further directs the IRS to "convey to ICE the [IRS]'s own expectation that ICE will handle [the previously transferred] information consistent with the Court’s holdings and the safeguards that Congress established." Though the court primarily considered address-sharing, it also found that Plaintiffs plausibly alleged that the IRS's broader data-sharing policy is unlawful. Ctr. for Taxpayer Rights v. IRS, No. 1:25-cv-00457 (D.D.C.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2026.02.05 Order - CEDC v. Bessent

U.S. District Judge Indira Talwani issued a preliminary injunction to halt ICE's use of taxpayer-address data obtained from the IRS. The court held that the agencies likely violated the Tax Reform Act and the Administrative Procedure Act by implementing data-sharing agreements bypassing statutory privacy protections in 26 U.S.C. § 6103. The court determined that ICE's requests failed to comply with Section 6103's requirements, and that ICE further engaged in "impermissible use" of the data by cross-referencing records and storing them on an unauthorized computer. The order stays the data-sharing arrangement and prohibits ICE from "inspecting, viewing, using, copying, distributing, relying on or otherwise acting upon" any information received under these agreements. Cmty. Econ. Dev. Ctr. of SE Mass. v. Bessent, No. 25-cv-12822 (D. Mass.).

**Link to case here. See litigation note above**

Subsequent Trump and Court Action

2026.02.11 Declaration of Dottie Romo - CEDC v. Bessant

A declaration filed by Dottie Romo, the IRS chief risk and control officer, admitted to improperly sharing confidential tax data of thousands of immigrants with DHS. The breach occurred under an April 2025 agreement between the Treasury and DHS. (It is unclear whether the April 2025 agreement was the MOU listed above or a separate, undisclosed implementation agreement.)

While the agreement called for the IRS to only confirm the last known address of people whose names and addresses were provided by DHS, the court declaration revealed that the agency erroneously and additionally provided last known addresses for thousands of individuals for whom DHS lacked sufficient information to positively identify them.

According to reporting by the Washington Post, Romo's declaration declined to state whether the IRS would inform people whose data was illegally shared with immigration officials of the breach. Romo stated that DHS and ICE had agreed to “not inspect, view, use, copy, distribute, rely on, or otherwise act on any return information that has been obtained from or disclosed by IRS” because of the pending litigation. Cmty. Econ. Dev. Ctr. of SE Mass. v. Bessent, No. 25-cv-12822 (D. Mass.).

**Link to case here. See litigation note above**