IRS–ICE Taxpayer Data Sharing: Centro de Trabajadores Unidos v. Bessent

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On February 24, 2026 the D.C. Circuit let the IRS keep sharing taxpayer addresses with ICE, but two district-court injunctions still block large-scale sharing.

Status: Partially blocked — Centro de Trabajadores Unidos v. Bessent (D.C. Cir. No. 25-5181 (aff'g D.D.C. No. 1:25-cv-00677, Friedrich, J.))

On February 24, 2026, the D.C. Circuit affirmed a district court ruling and allowed the IRS to keep sharing taxpayer address information with ICE. The three-judge panel (Judges Srinivasan, Millett, and Edwards; opinion by Judge Edwards) held that 26 U.S.C. § 6103(i)(2) authorizes the IRS to disclose a taxpayer's name and address to named immigration officials for use in a non-tax criminal investigation, and that a name and address are not protected "taxpayer return information" under that provision. The court said this authority covers criminal immigration investigations only, not civil immigration enforcement, and that the IRS–ICE memorandum of understanding (MOU) is a nonbinding policy statement, not a final agency action that courts can review. That ruling resolved only the injunction request in this one case; the IRS–ICE information-sharing arrangement is not, however, freely operative: in two separate lawsuits federal district courts have blocked large-scale sharing — the U.S. District Court for the District of Columbia (Center for Taxpayer Rights v. IRS, November 2025) and the U.S. District Court for Massachusetts (Community Economic Development Center v. Bessent, February 2026) — and as of September 1, 2026 (dockets re-checked) those injunctions remain in place while the litigation continues on appeal. On **September 8, 2026** a different D.C. Circuit panel decided the companion appeal and went the other way on the bulk procedure: in *Center for Taxpayer Rights v. IRS*, No. 26-5006 (Millett, Pillard and Wilkins; opinion by Judge Pillard), the court **affirmed** the district court's stay of the IRS's Data-Exchange Procedure and its preliminary injunction against further disclosures without notice to the court. The opinion records that ICE Acting Director Todd Lyons asked the IRS on June 27, 2025 for the last known address of **1.28 million** people, and that the IRS **had turned over more than 47,000 records** before the district court stopped it. The two rulings are consistent: a properly-supported, individual §6103(i)(2) request tied to a non-tax criminal investigation can stand, while the bulk procedure could not.

Next step: The Center for Taxpayer Rights case returns to the U.S. District Court for the District of Columbia for the merits; the September 8, 2026 ruling was on a preliminary injunction. The government may seek rehearing en banc or Supreme Court review in either appeal, and separate cases in other courts are still testing IRS-ICE data sharing, so the rules can change.

Last editorial review: 2026-09-10 — status can change with a single court ruling. Official source.

What’s happening

On February 24, 2026, the D.C. Circuit affirmed a district court ruling and allowed the IRS to keep sharing taxpayer address information with ICE. The three-judge panel (Judges Srinivasan, Millett, and Edwards; opinion by Judge Edwards) held that 26 U.S.C. § 6103(i)(2) authorizes the IRS to disclose a taxpayer’s name and address to named immigration officials for use in a non-tax criminal investigation, and that a name and address are not protected “taxpayer return information” under that provision. The court said this authority covers criminal immigration investigations only, not civil immigration enforcement, and that the IRS–ICE memorandum of understanding (MOU) is a nonbinding policy statement, not a final agency action that courts can review. That ruling resolved only the injunction request in this one case; the IRS–ICE information-sharing arrangement is not, however, freely operative: in two separate lawsuits federal district courts have blocked large-scale sharing — the U.S. District Court for the District of Columbia (Center for Taxpayer Rights v. IRS, November 2025) and the U.S. District Court for Massachusetts (Community Economic Development Center v. Bessent, February 2026) — and as of September 1, 2026 (dockets re-checked) those injunctions remain in place while the litigation continues on appeal. On September 8, 2026 a different D.C. Circuit panel decided the companion appeal and went the other way on the bulk procedure: in Center for Taxpayer Rights v. IRS, No. 26-5006 (Millett, Pillard and Wilkins; opinion by Judge Pillard), the court affirmed the district court’s stay of the IRS’s Data-Exchange Procedure and its preliminary injunction against further disclosures without notice to the court. The opinion records that ICE Acting Director Todd Lyons asked the IRS on June 27, 2025 for the last known address of 1.28 million people, and that the IRS had turned over more than 47,000 records before the district court stopped it. The two rulings are consistent: a properly-supported, individual §6103(i)(2) request tied to a non-tax criminal investigation can stand, while the bulk procedure could not.

Who it affects

People who file U.S. taxes with an Individual Taxpayer Identification Number (ITIN) or who otherwise have a return on file with the IRS, including immigrants without lawful status. Under the D.C. Circuit’s reasoning, Section 6103 would let the IRS give ICE the name and address on file for a qualifying request tied to a non-tax criminal investigation; however, separate district-court injunctions currently block large-scale sharing. The decision does not authorize sharing for civil immigration enforcement, and it does not open up the contents of a tax return, such as income, dependents, or deductions.

How it got here

Mar 7, 2025 Lawsuit filed in the U.S. District Court for the District of Columbia, challenging IRS plans to share taxpayer data with immigration authorities.
Apr 7, 2025 The IRS and ICE sign a Memorandum of Understanding setting up procedures to share taxpayer information for criminal immigration enforcement.
May 12, 2025 The district court (Judge Dabney Friedrich) denies the preliminary injunction, finding the IRS likely could lawfully share address data with ICE solely to support a criminal investigation, not for civil enforcement.
May 21, 2025 Plaintiffs appeal the denial of the preliminary injunction to the D.C. Circuit.
Nov 21, 2025 In a separate suit, the U.S. District Court for the District of Columbia (Center for Taxpayer Rights v. IRS) issues a preliminary injunction restricting the IRS from sharing taxpayer data with ICE except in strict compliance with Section 6103.
Feb 5, 2026 The U.S. District Court for Massachusetts (Community Economic Development Center v. Bessent) enjoins ICE and DHS from viewing, using, or acting on return information obtained under the agreement.
Feb 24, 2026 The D.C. Circuit (Judges Srinivasan, Millett, and Edwards; opinion by Judge Edwards) affirms, holding that 26 U.S.C. § 6103(i)(2) authorizes the IRS to disclose taxpayer addresses for use in non-tax criminal investigations.
Jun 30, 2026 As of mid-2026, the two district-court injunctions remain in place and block large-scale transfers while appeals continue; the practical availability of the data-sharing is contested.
Sep 8, 2026 The D.C. Circuit (Millett, Pillard, Wilkins; opinion by Judge Pillard) affirms the district court's stay of the IRS Data-Exchange Procedure and its preliminary injunction against further disclosures without notice to the court, in Center for Taxpayer Rights v. IRS, No. 26-5006. More than 47,000 records had already been disclosed; ICE's June 27, 2025 request covered 1.28 million people.

What to watch next

The lawsuit continues on the merits in the U.S. District Court for the District of Columbia. The plaintiffs may also seek rehearing by the full D.C. Circuit (en banc) or review by the U.S. Supreme Court. Separate cases in other courts are also testing IRS–ICE data sharing, so the rules can still change.

Official sources

This page is general information about ongoing litigation, not legal advice. A case’s status can change with a single ruling, and outcomes can turn on facts specific to each person. For advice on a specific situation, consult a licensed immigration attorney or a DOJ-accredited representative.

Frequently asked questions

What is this case about?

Where does it stand right now?

On February 24, 2026, the D.C. Circuit affirmed a district court ruling and allowed the IRS to keep sharing taxpayer address information with ICE. The three-judge panel (Judges Srinivasan, Millett, and Edwards; opinion by Judge Edwards) held that 26 U.S.C. § 6103(i)(2) authorizes the IRS to disclose a taxpayer’s name and address to named immigration officials for use in a non-tax criminal investigation, and that a name and address are not protected ’taxpayer return information’ under that provision. The court said this authority covers criminal immigration investigations only, not civil immigration enforcement, and that the IRS–ICE memorandum of understanding (MOU) is a nonbinding policy statement, not a final agency action that courts can review. That ruling resolved only the injunction request in this one case; the IRS–ICE information-sharing arrangement is not, however, freely operative: in two separate lawsuits federal district courts have blocked large-scale sharing — the U.S. District Court for the District of Columbia (Center for Taxpayer Rights v. IRS, November 2025) and the U.S. District Court for Massachusetts (Community Economic Development Center v. Bessent, February 2026) — and as of September 1, 2026 (dockets re-checked) those injunctions remain in place while the litigation continues on appeal. On September 8, 2026 a different D.C. Circuit panel decided the companion appeal and went the other way on the bulk procedure: in Center for Taxpayer Rights v. IRS, No. 26-5006 (Millett, Pillard and Wilkins; opinion by Judge Pillard), the court affirmed the district court’s stay of the IRS’s Data-Exchange Procedure and its preliminary injunction against further disclosures without notice to the court. The opinion records that ICE Acting Director Todd Lyons asked the IRS on June 27, 2025 for the last known address of 1.28 million people, and that the IRS had turned over more than 47,000 records before the district court stopped it. The two rulings are consistent: a properly-supported, individual §6103(i)(2) request tied to a non-tax criminal investigation can stand, while the bulk procedure could not. The lawsuit continues on the merits in the U.S. District Court for the District of Columbia. The plaintiffs may also seek rehearing by the full D.C. Circuit (en banc) or review by the U.S. Supreme Court. Separate cases in other courts are also testing IRS–ICE data sharing, so the rules can still change.

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General information, not legal advice. MigrantUSA is an independent publisher and is not a law firm; using this site does not create an attorney-client relationship, and this content is not a substitute for advice from a licensed attorney about your specific situation. US federal, state, and local government procedures, fees, and forms change. Always verify current details directly with the relevant agency before acting. For immigration, tax, or other legal matters specific to your situation, consult a licensed attorney or BIA-accredited representative.