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Implications of IRS-ICE Data Sharing

The IRS-ICE data-sharing agreement signed on April 7, 2025, is a historic and controversial shift in U.S. tax and immigration policy. It has broad implications for how information returns—including Forms 1042-S, 1099, and W-2—are filed, verified, and enforced.

Overview of the Agreement

  • Signed by: Treasury Secretary Scott Bessent and DHS Secretary Kristi Noem

  • Effective Date: April 7, 2025

  • What it does: Authorizes Immigration and Customs Enforcement (ICE) to access select IRS taxpayer data, including:

    • Tax filings using ITINs (Individual Taxpayer Identification Numbers)

    • Information returns like 1042-S, 1099 series, and W-2

    • Withholding data and treaty benefit claims

  • Trigger Conditions: Applies in cases where ICE is pursuing immigration enforcement against individuals with final deportation orders or criminal investigations involving fraud or identity misuse.

Why the IRS-ICE Agreement Affects Information Returns

Tax Data Can Now Trigger Immigration Enforcement

  • The IRS is sharing tax data—including information return data—with ICE.

  • If someone files a return or is listed on a form (like a 1042-S or 1099) using an ITIN or a possibly false SSN, ICE can now use that to:

    • Track income and employment

    • Check if someone is violating immigration laws (e.g., overstaying a visa, working without authorization)

Information returns are forms that report who got paid, how much, and whether taxes were withheld. This agreement between ICE and the IRS makes information returns a tool for immigration enforcement.

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