Courts told ICE it couldn’t get immigrant tax data through the front door. Procurement records suggest the agency found another entrance. A contract worth approximately $9.97 million, awarded June 5 to federal IT reseller Thundercat Technology LLC, provides ICE agents with “ITIN data subscription and analytics” — access to information linked to Individual Taxpayer Identification Numbers. ITINs are nine-digit tax IDs the IRS created in 1996 so people without Social Security numbers, primarily undocumented immigrants, could file returns and pay taxes. The implicit promise was straightforward: comply with tax law, and that information stays confidential.

The Loophole With a Price Tag

Federal law blocks the IRS from sharing tax data with ICE, but says nothing about buying equivalent information from a commercial broker.

The timeline tells the story:

• On April 7, 2025, the IRS and ICE signed a memorandum of understanding allowing limited taxpayer data sharing.
• By August, litigation revealed ICE had requested over one million taxpayer records.
• On November 21, a federal judge blocked further sharing, finding the arrangement likely unlawful under IRC §6103 — the statute protecting tax-return confidentiality.
• Then came the Thundercat contract.

The injunction targeted IRS disclosures, not commercial purchases. That gap is the whole story.

Thundercat operates as a reseller and systems integrator. Which underlying data broker actually holds the ITIN-linked records remains unconfirmed in public filings. Meanwhile, roughly 90 percent of HSI staff have reportedly been redirected to immigration enforcement under current directives, according to Cato Institute researchers.

• IRS–ICE MOU signed April 7, 2025; ICE subsequently requested over one million taxpayer records
• Federal judge blocked further IRS sharing on November 21, 2025, citing a likely unlawful arrangement
• Thundercat is a known federal IT reseller; the underlying data source remains unidentified in public records
• Approximately 90 percent of HSI staff reportedly shifted to immigration enforcement under current directives

Fraud as Cover, Questions Remain

The contract references fraud investigations, but ICE’s track record with that label raises serious questions about scope.

Tax and immigration policy experts warn this approach “radically weaponizes the trust” undocumented immigrants placed in the IRS, according to analysis published by the University of Cincinnati’s human rights law review. This contract slots into ICE’s existing commercial surveillance stack — Thomson Reuters CLEAR, LexisNexis Risk Solutions, license-plate readers, Clearview AI facial recognition. The pattern is documented and deliberate: assemble a commercial data dragnet, piece by piece, much like the surveillance app built to target specific communities.

The contract does not specify whether agents receive full identity profiles tied to ITINs or narrower analytics. HSI has previously used “fraud investigation” framing as an entry point for broad immigration sweeps, including operations targeting Somali immigrant communities in Minnesota. The operational guardrails here remain, at best, opaque. These are among the more troubling tech scandals to emerge from the intersection of commercial data markets and government enforcement.

Treasury maintains the original MOU relied on longstanding criminal-investigation authorities under §6103(i)(2), targeting only individuals with final removal orders. Civil-liberties groups and Senator Wyden counter that purchasing commercially equivalent data deliberately circumvents both congressional intent and judicial rulings — a concern echoed by reports of apps secretly tracking users without meaningful oversight. The Fourth Amendment Is Not For Sale Act would close this loophole. It has not passed.

If this contract stands unchallenged, it sets a template: lose in court, open a purchase order. Tax Policy Center analysts warn that declining ITIN filing rates could cost federal revenue alongside immigrant trust. The people who followed the rules may have handed over the evidence themselves.