Chamberlain Hrdlicka

Tax Controversy & Litigation Criminal Tax Defense International Tax State and Local Tax Controversy & Planning Internal Investigations Federal White Collar Criminal Defense Tax Paycheck Protection Program (PPP) Audits and Investigations

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Kevin Sweeney is an experienced tax attorney and former federal prosecutor who specializes in defending clients in civil and criminal tax controversy and litigation matters. He focuses on high-stakes IRS audits, civil tax litigation, white-collar criminal defense and investigations, and whistleblower matters for high and ultra-high net worth individuals, corporate executives, business owners, and public and private companies worldwide. Kevin also utilizes this litigation experience to assist tax planners at his firm in designing transactions that will withstand IRS and state taxing authority scrutiny. His 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 federal and state taxing authorities.

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 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. 

Kevin served on active duty as a judge advocate (JAG) in the United States Army from 2006-2010 and the Army Reserve from 2010-2016. After graduating from Airborne School in 2006, Kevin deployed to Iraq 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, he served first as a prosecutor at Fort Hood and then as an appellate attorney in Washington, DC. As a JAG, Kevin litigated dozens of criminal cases and appeals.

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 defending against IRS/DOJ attempts to compel evidence during civil audits and criminal investigations to include Fifth Amendment and privilege assertions. 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. 

Loyola University Maryland, B.B.A. (Accounting) 2002

New York Law School, J.D. 2005 (Cum Laude)