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Thomas E. Zehnle

Thomas Zehnle has more than 25 years of experience in tax, white collar and civil litigation. He brings a broad perspective to handling such matters, having served as a defense lawyer, a federal prosecutor and as the chief of a U.S. Department of Justice (DOJ) criminal enforcement section supervising tax fraud prosecutions across the United States. He maintains a diverse practice, representing corporations, partnerships, accounting firms, professional service providers and individuals who have been indicted, or who are involved in grand jury investigations, federal regulatory actions and civil disputes.

Throughout his career, Mr. Zehnle has tried numerous cases to verdict and has successfully handled investigations involving allegations of tax evasion, accounting and securities fraud, money laundering, conspiracy, false claims and Bank Secrecy Act (BSA) violations. He regularly represents clients with respect to examinations of complex tax shelters. Further, Mr. Zehnle counsels and advises individuals, financial professionals and financial institutions regarding undisclosed foreign assets and accounts. He has substantial experience conducting internal investigations of potential corporate misconduct. Mr. Zehnle has also been selected and approved by federal and state agencies as an independent monitor on numerous occasions, and has conducted examinations of publicly-traded and private companies pursuant to agreements mandated by the DOJ, the Securities and Exchange Commission (SEC) and state enforcement agencies.

Mr. Zehnle is the author of dozens of articles relating to tax, white collar, and civil litigation and he has been frequently published in legal journals and periodicals. He has been quoted often in media outlets such as The New York Times, BusinessWeek, Bloomberg News and BNA. Mr. Zehnle is also a regular lecturer, appearing at conferences and seminars sponsored by the American Bar Association, the Federal Bar Association, the DOJ, the Internal Revenue Service (IRS) and the Society of Trust and Estate Practitioners.

Representative Engagements|View All

Criminal

  • Independent Examinations of Foreign Financial Institutions. Retained by multiple foreign financial institutions to serve as an Independent Examiner pursuant to the U.S. Department of Justice program involving the banks' cross-border business and the use of undeclared accounts by U.S. persons.
     
  • United States v. Amrein, No. 13-cr-972 (S.D.N.Y. filed Dec. 17, 2013). Representing a foreign asset manager with respect to an alleged criminal tax conspiracy involving undeclared accounts held by U.S. persons. The matter is pending. 

Civil

  • Starr Int'l Co. v. United States, No. 14-cv-1593 (D.D.C. filed Sept. 19, 2014) Represents a global insurance company in a multi-million dollar refund suit alleging that the U.S. government abused its discretion in denying benefits under the U.S.-Swiss tax treaty. This is a case of first impression where the court has ruled that it will determine if the Internal Revenue Service abused its discretion. The matter is pending. 
     
  • Representing a professional service provider in a civil penalty audit where the IRS alleges that the client established, participated in and promoted listed tax shelters that resulted in more than $100 million in improper tax deductions. The IRS has asserted over $13 million in penalties against the client. The matter is pending. 
Government Experience
  • Chief, Criminal Enforcement Section (Southern), Tax Division, U.S. Department of Justice, 2001 - 2004 
  • Counsel to Assistant Attorney General, Tax Division, U.S. Department of Justice, 2000 - 2001 
  • Trial Attorney, Criminal Enforcement Section (Southern), Tax Division, U.S. Department of Justice, 1990 - 2000
Corporate Experience
Rankings and Recognition
  • Chambers USA: Tax Fraud (National), 2016
  • Chambers USA: Tax Fraud (National), Recognized Practitioner, 2015
  • International Tax Review: Tax Controversy Leaders (U.S.), 2015
  • Legal 500: Tax: Tax Controversy, 2014 - 2015
  • Legal 500: Litigation: White-Collar Criminal Defense, 2012, 2014
  • U.S. Department of Justice (management awards), 2002 - 2004
  • Internal Revenue Service, Honorary Awards, 1995, 2000
  • U.S. Department of Justice Outstanding Attorney Awards, 1994, 1998
  • Selected to the Senior Executive Service of the United States of America
Professional and Community Involvement
  • Fellow, American College of Tax Counsel
  • Member, National Association of Criminal Defense Lawyers 
  • Co-Chair, American Bar Association, Criminal Justice Section’s Tax Enforcement Subcommittee 
  • Associate Editor, American Bar Association, Litigation News
Bar Admissions
  • District of Columbia
  • Virginia
Court Admissions
  • United States District Court for the Eastern District of Virginia
  • United States District Court for the District of Columbia
  • United States District Court for the District of Maryland
  • United States Court of Appeals for the Fourth Circuit
  • United States Tax Court
Clerkships
Foreign Languages
Education
  • J.D., College of William and Mary, 1987
  • A.B., University of Missouri-Columbia, with honors, 1984