Kevin Sweeney

IRS audits, civil tax litigation, and white-collar criminal defense

10+ Years of Experience

Tax Law, White Collar Crime ...

Pennsylvania.

Kevin Sweeney is a former federal tax prosecutor with over a decade of experience. His practice focuses on high-stakes IRS audits, tax litigation, white-collar criminal defense matters, and corporate investigations for entities and individuals all over the world. Kevin’s experience and longstanding connections enable him to anticipate government action, expertly navigate clients through difficult situations, and deliver arguments that resonate with judges, juries, prosecutors, and IRS employees.

Tax Law: Business Taxes, Criminal Tax Litigation, Estate Tax Planning, Income Taxes, International Taxes, Payroll Taxes, Property Taxes, Sales Taxes, Tax Appeals, Tax Audits, Tax Planning

White Collar Crime

New Jersey
Since 2005

Languages

English:
Spoken, Written

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Chamberlain, Hrdlicka, White, Williams & Aughtry

2016 –

Current

Kevin counsels companies and individuals on tax compliance matters and defends them in IRS audits and civil tax litigation before the United States Tax Court, District Courts, Circuit Courts, and Court of Federal Claims. He draws on his prior experience as a trial attorney for the U.S. Department of Justice’s Tax Division (DOJ). Kevin’s skill set is particularly suited for complex civil tax issues as well as sensitive tax matters where penalty, fraud, or even criminal issues could arise. He has successfully assisted clients with cases involving offshore and foreign tax information reporting, reports of foreign bank and financial accounts (FBARs), cryptocurrency, tax credits, tax shelters, captive insurance, reportable transactions, material adviser disclosure statements, employment taxes, passive activity loss rules, hobby loss rules, mark-to-market elections, like-kind exchanges, promoter audits, trust fund recovery penalties and preparer penalties. Kevin has also assisted clients with state sales tax and residency issues. In cases where a civil tax disposition is not possible, Kevin counsels and defends clients in IRS administrative investigations, grand jury investigations, and federal prosecutions. As a former federal tax prosecutor for DOJ Tax and several U.S. Attorney’s Offices, he is a seasoned white-collar criminal defense attorney. Kevin has investigated and litigated dozens of federal financial fraud cases throughout the country involving tax evasion, tax preparer, employment tax, FBAR, money laundering, currency structuring, Foreign Corrupt Practices Act (FCPA), and other financial fraud issues. Cases Kevin has litigated have been covered by Fortune, Bloomberg, and The Financial Times. Kevin frequently speaks and writes on civil and criminal tax controversy and litigation matters and is often quoted by national media outlets including the Wall Street Journal, CNBC and CNN. He wrote the book on IRS/DOJ authority to compel documents and testimony with summonses and subpoenas during civil audits and criminal investigations as well as available defenses and privilege issues. See Bloomberg Tax Portfolio, Compelled Production of Documents and Testimony in Tax Examinations, No. 633. Kevin is admitted to practice law in New York, New Jersey, and Pennsylvania.

Trial Attorney

U.S. Department of Justice, Tax Division

2010 –

2016

Kevin is uniquely positioned to counsel financial institutions, asset managers, professional services firms, and executives on U.S. regulatory and tax enforcement issues including FATCA and to represent individuals with foreign bank accounts and virtual currency wallets in civil tax audits, criminal tax investigations, voluntary disclosures, and other IRS tax compliance matters. At DOJ Tax he was part of a select team of attorneys who specialized in offshore tax enforcement matters. He led many of the offices most successful international cases including landmark tax enforcement actions against Swiss banks BSI SA, Union Bancaire Privée (UBP) SA, and Edmond de Rothschild SA.

Judge Advocate (JAG)

U.S. Army Judge Advocate General’s (JAG) Corps

2006 –

2010

Kevin served on active duty from 2006-2010. He deployed to Baghdad, Iraq in 2006 with the 4th Infantry Division where he advised commanders on criminal law issues and internal investigations into serious combat-related incidents. Upon returning from Iraq, Kevin served first as a prosecutor in Fort Hood, Texas and then as an appellate attorney in Washington, DC. As a JAG, Kevin investigated and litigated dozens of criminal cases and appeals.