Agencies involved in the search included the Internal Revenue Service's Criminal Investigation Division, the U.S. Department of Commerce's Bureau of Industry and Security's Office of Export Enforcement, and the Federal Deposit Insurance Corp.'s Office of Inspector General, the U.S. Attorney Office's Paul said.

Caterpillar is fighting an Internal Revenue Service demand that the company pay $2 billion in taxes and penalties for profits assigned to a Swiss parts distribution subsidiary, Caterpillar SARL, or CSARL, according to filings with the Securities and Exchange Commission. That subsidiary was also the subject of a 2014 Senate committee report that charged Caterpillar "shifted billions of dollars in profits away from the United States."

Caterpillar, in its annual report, said it is "vigorously contesting" the IRS demand. "We believe that the relevant transactions complied with applicable tax laws and did not violate judicial doctrines," Caterpillar stated.

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