The Department of Justice (DOJ) has finalized a restructuring move where all functions of former Tax Division will transfer to both Civil Division and Criminal Division, with a new regulation that took effect on Dec. 9, 2025, according to Bloomberg Tax.

The DOJ begins with an explanation in the preamble of this regulation, referring to an executive order issued by President Donald Trump on Feb. 11, 2025, referring to restoring accountability to the American public with a goal of “eliminating waste, bloat, and insularity,” so that it can “better serve the American public through more efficient operations,” according to Taxnotes.

On a substantive level, “the organizational rule transfers certain functions within the Department," and on the civil side, it includes a specific designated heading for ‘civil tax litigation,' which encompasses prosecution and defense in all Courts, other than the Tax Court, of civil suits … arising under the internal revenue laws,' and other matters involving liens, injunctions, and other matters under the internal revenue laws.

On the criminal side, it assigned the Criminal Division with handling all matters pertaining to “all criminal proceedings arising under the internal revenue laws.”

The final regulation contains other standard organizational changes following an organizational change, such as removing the "Tax Division" from the organizational chart of DOJ, striking a subpart and reserving it, and striking former directives and citations referring cases via the former division. 

Bloomberg Tax points out that this move is seen by some critics as a way of sending a message that tax enforcement will not be a priority.