Kevin Sweeney

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.

New York Law School

J.D. (2005) | Law

2002 - 2005

Honors: Cum Laude

Loyola College

B.B.A. (2002) | Accounting

1998 - 2002

Shareholder

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.

Compelled Production of Documents and Testimony in Tax Examimations

Bloomberg Tax Portfolio, No. 633

Specifically Identifying Exchanges-Based Crypto: An Old Solution to a New Problem

Bloomberg Tax

April 15, 2019

Keeping a Lid on the Crypt: Protecting Taxpayers’ Fifth Amendment Rights to Not Produce Incriminating Crypto Tax Records

CCH Journal of Tax Practice & Procedure 20-5 Issue

February, 2019

Defending Business Executives Against Personal Sales Tax Liabilities in Pennsylvania

PICPA’s CPA Now

December 5, 2018

Don’t Miss the U.S. Tax Compliance Boat - OVDP Ends Sept 18

Expat Network

September, 2018

Employment Taxes and Criminal Prosecutions, Fall Meeting, Boston, MA

September 30, 2016

American Bar Associatiom Tax Section

Eggshell Audits: Handling IRS Examinations With Potential Fraud Penalty and Criminal Issues, Dinner Meeting, Monroe Township, NJ

November 9, 2016

New Jersey Society of Enrolled Agents

Criminal Tax Workshop, 34th National Institute on Criminal Tax Fraud & 7th Annual National Institute on Tax Controversy, Las Vegas, NV

December 7, 2016

American Bar Association Tax Section

Navigating the Minefield: Strategies for Establishing and Preserving the Attorney Client Privilege During Internal Investigations, Breakfast Meeting, Philadelphia, PA

April 25, 2017

Philadelphia Area Chapter of Certified Fraud Examiners

Hot Topics in Tax and Money Laundering Viewed Through the Lens of United States v. Paul Manafort, White-Collar Practice Seminar, Philadelphia, PA

November 16, 2018

Pennsylvania Association of Criminal Defense Lawyers

Listed

Legal 500

2017

Outstanding Attorney Award

U.S. Department of Justice, Tax Division

2015

Outstanding Attorney Award

U.S. Department of Justice, Tax Division

2013

American Bar Association Section on Taxation

Civil and Criminal Tax Penalties Committee

Current

American Bar Association Section on Criminal Justice

White-Collar Crime Committee

Current

New Jersey

Since 2005

New York

Since 2005

Pennsylvania

Since 2017

U.S. Supreme Court

Since 2010