It’s no secret that the IRS workforce has shrunk under the Trump administration. By one count, the agency shed nearly 28,000 workers at the end of 2025. What might be less clear, though, is what precise types of enforcement the IRS will prioritize with a slimmed-down workforce.
Speaking at the Illinois CPA Society’s 2026 summit last week, Kathy Enstrom, chief operating officer and director of investigations with the Chicago-based Moore Tax Law Group, took a stab at detailing a few of the chief areas the IRS is likely to target these days.
Enstrom, a former IRS executive herself, based her presentation, in part, on recent comments made by IRS Criminal Investigation Chief Jarod Koopman. Here are a few key takeaways for finance leaders.
1. Nonprofits under increased scrutiny
In a March 16 executive order establishing a “task force to eliminate fraud,” President Donald Trump specifically mentioned the $250 million fraud scandal perpetrated by the Minnesota nonprofit Feeding Our Future. The group said it was using federal dollars to distribute meals to children, but prosecutors said that only a small percentage of funds were actually used for that purpose.
It may come as no surprise, then, that the Trump administration’s IRS is taking a closer look at nonprofits across the board.
Enstrom said the IRS has indicated it will continue keeping watch on nonprofits, especially those that receive federal dollars.
“Nonprofits are going to be on their radar, as well as anything regarding government program fraud,” she told a crowd of accountants and other financial leaders at the Donald E. Stephens Convention Center in Rosemont, Illinois.
2. Employment tax schemes remain an easy target
One longstanding area of focus for the IRS is employment taxes, said Enstrom. If a business chooses not to pay employment taxes, “it racks up really quickly.”
Enstrom said the agency has been targeting such schemes for decades and may have even more reason to dig into them now.
“It’s like shooting fish in a barrel for the IRS, and unfortunately, the IRS only has so many resources,” she said. “When it’s easy to find, it’s easy to investigate.”
3. Cross-border and international tax schemes are being watched
IRS leaders have indicated that crimes involving cross-border activity will be a “major priority,” Enstrom said.
As an example, she pointed to abuses of Puerto Rico’s Act 60, which is a tax incentive designed to bring businesses and investors to the island territory. To qualify for the incentive, individuals or businesses need to prove they’ve relocated to Puerto Rico for a set amount of time. However, some people are abusing the law by claiming to live on the island when they don’t actually meet residency requirements.
Various promoters and scammers continue to peddle false claims about Act 60, Enstrom noted. There are also various offshore pension schemes that could find themselves in IRS crosshairs.
4. Digital assets still carry risks
Though the Trump administration appears to have taken a friendlier stance toward cryptocurrency and other assets, with the president himself reportedly raking in more than $1 billion from his crypto ventures, there has been some enforcement activity in the area.
Enstrom pointed to the case of Goliath Ventures, whose president and CEO Alexander Delgado was arrested in February of this year over allegations of running a crypto-based Ponzi scheme. Prosecutors said at the time Delgado obtained at least $328 million from victim investors.
Enstrom said the IRS criminal investigation unit is “very focused on cryptocurrency.” Koopman, who heads that unit, also “knows crypto back and forth.”
She urged attendees to remain cautious about digital assets.
