Kevin F. Sweeney, senior counsel at Chamberlain Hrdlicka in Philadelphia and a former federal tax prosecutor, will participate in a panel on cryptocurrency taxation at the 35th National Institute on Criminal Tax Fraud and Eighth Annual National Institute on Tax on Dec. 13-15 in Las Vegas. Hosted by the American Bar Association, the annual conference brings together high-level government representatives, judges, corporate counsel and private practitioners engaged in all aspects of tax controversy, tax litigation and criminal tax prosecutions and defense.
The substantive panel, “What Everyone Needs to Know About Cryptocurrency,” will provide insight on the tax treatment of cryptocurrency transactions and enforcement when cryptocurrency transactions go wrong. With cryptocurrency dominating the concern of all government regulators, Sweeney and his panelists will address the income tax consequences of owning, trading and investing in cryptocurrency and enforcement issues facing the IRS, as well as enforcement under the Bank Secrecy Act (BSA). Sweeney also expands on many of the same issues in an article to be published in the upcoming October/November 2018 issue of CCH Journal of Tax Practice and Procedure, “Keeping a Lid on the Crypt: Protecting Taxpayers’ Fifth Amendment Rights to Not Produce Incriminating Crypto Records.”
Prior to joining Chamberlain Hrdlicka, Sweeney was a trial attorney for the U.S. Department of Justice’s Tax Division (DOJ Tax) in Washington, DC, where he led many of the most successful tax enforcement cases and identified, investigated, recommended for IRS audit, and criminally prosecuted U.S. foreign bank account holders.
Now in private practice, Sweeney represents clients in federal and state tax audits, tax collection matters, and litigation in United States Tax Court, District Courts, and Court of Federal Claims including sensitive matters where penalty, fraud, or criminal issues could arise. He has handled an array of high-stakes civil tax controversy and litigation issues as well as criminal tax investigations and prosecutions, including matters related to cryptocurrency, security tokens, captive insurance and offshore bank accounts.