Dan's practice focuses on representing taxpayers in federal and state tax litigation and controversies as well as transactional planning involving corporate, franchise, personal income and sales/use tax matters. Prior to his employment at Sullivan, Dan was an attorney at the Internal Revenue Service Office of Chief Counsel, where he represented the Internal Revenue Service in litigation before the United States Tax Court and served as a Special Assistant United States Attorney for the District of Massachusetts.
Dan is also one of the founders of the firm's Opportunity Zone practice group, and has assisted in the structuring of over $1 billion in Opportunity Zone projects throughout the country, including both real estate and operating business. Dan was named a Top 25 Tax Specialist by Opportunity Zone Magazine in 2022.
Dan is a frequent speaker on such matters as Opportunity Zone tax structuring, federal tax credits, federal and state controversy issues, and domicile planning. Dan has also been quoted on various tax matters in publications such as the Boston Globe, the Boston Herald, Law360, The Real Deal and Bloomberg Tax.
Dan has successfully represented clients under audit before the Internal Revenue Service and various state departments of revenue on a wide range of matters. For example, Dan successfully secured a multi-million dollar refund for an insurance company before the Massachusetts Supreme Judicial Court in Dental Service of Massachusetts v. Commissioner, a case of first impression in Massachusetts. Dan has also represented clients in domestic and offshore voluntary disclosures, and has successfully negotiated the abatement of federal tax penalties imposed based on various offshore tax issues.
Representative Client Work
- Provided tax structuring advice on the recapitalization of an art storage business that relocated into an Opportunity Zone
- Represented an international distributor of electronic components in a dispute with the Massachusetts Department of Revenue over whether the corporation and its wholly-owned subsidiary conducted a unitary business
- Negotiated a full concession by the IRS of a proposed $10 million tax assessment and civil fraud penalties against an individual taxpayer
- Secured a multi-million dollar refund of Massachusetts insurance premium excise following a trial before the Massachusetts Appellate Tax Board, and successfully argued an appeal of the decision before the Massachusetts Supreme Judicial Court
- Secured a multi-million dollar refund of a Massachusetts utility corporation excise for the owner of a power plant
- Represented an individual on trial for federal tax crimes
- Represented individuals and corporations in litigation involving the IRS before the United States Tax Court and United States District Court
- Represented clients during IRS audits and at the IRS Office of Appeals on matters involving partnership taxation, estate and gift tax, and individual and corporate income tax
- Provided assistance to clients in controversies involving the Massachusetts Department of Revenue at the administrative level and before the Appellate Tax Board, including individual domicile audits and other income tax issues, as well as matters involving corporate excise and sales and use taxes
Bar & Court Admissions
- Massachusetts
- New York
- U.S. District Court, District of Massachusetts
- U.S. Tax Court
Education
- LL.M., Taxation, Boston University School of Law
- J.D., magna cum laude, Catholic University, Columbus School of Law
- B.A., Boston College
Community Engagement
- Boston Bar Association, Tax Section
- American Bar Association, Tax Section
Awards & Honors
- Top 25 Tax Specialist, Opportunity Zone Magazine (2022)
- The Legal 500 U.S. (2019, 2022)
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Law360, QuotedNovember 9, 2022
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Sampan, QuotedJuly 13, 2022
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Boston Herald, QuotedJune 22, 2022
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Boston Business Journal, QuotedJune 22, 2022
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Press ReleaseJune 8, 2022
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The Boston Globe, QuotedMay 5, 2022
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Boston Herald, QuotedMay 3, 2022
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Law360, QuotedApril 27, 2022
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Press ReleaseApril 26, 2022
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Client AlertApril 13, 2022
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Law360 Tax Authority, QuotedFebruary 23, 2022
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Press ReleaseFebruary 17, 2022
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GlobeSt.com, QuotedDecember 17, 2021
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Press ReleaseJune 9, 2021
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Law360, QuotedMay 19, 2021
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Client AlertMay 17, 2021
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GlobeSt.com, QuotedApril 23, 2021
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Client AlertApril 22, 2021
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Sullivan PublicationApril 20, 2021
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The Real Deal, QuotedApril 15, 2021
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Bloomberg Tax, QuotedApril 13, 2021
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Law360, QuotedApril 12, 2021
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Internal Revenue Service Provides Additional COVID-19 Related Relief for Opportunity Zones InvestorsClient AlertJanuary 20, 2021
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Bloomberg Tax, QuotedSeptember 23, 2020
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Client AlertJune 25, 2020
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Client AlertJune 17, 2020
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Client AlertJune 9, 2020
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Client AlertJune 1, 2020
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Client AlertMay 14, 2020
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Client AlertMay 14, 2020
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Client AlertMay 7, 2020
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Client AlertApril 30, 2020
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Client AlertApril 20, 2020
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Client AlertFebruary 11, 2020
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Sullivan Press ReleaseMay 30, 2019
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Opportunity Zones Client AlertApril 19, 2019
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Commercial Property Executive, QuotedJanuary 15, 2019
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Affordable Housing FinanceJanuary 11, 2019
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Real Estate Finance & Investment, QuotedJanuary 9, 2019
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Opportunity Zones AlertNovember 9, 2018
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Opportunity Zones AlertOctober 22, 2018
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Client AlertJune 13, 2018
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Client AdvisoryApril 18, 2018
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Law360April 13, 2018
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Client AdvisoryMarch 26, 2018
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Massachusetts Taxation and DOR PracticeJanuary 30, 2018
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Press ReleaseJanuary 8, 2018
Seminars & Presentations
- 'Millionaires Tax' Presentation
Worthy Circles (Webinar) (March 13, 2023) - Beyond the Basics: Compliance (Level 2): Dealing with the HR & Benefits Realities of Being a Multi-State Business
Sullivan & Worcester, Boston, MA (November 30, 2022) - Federal, State and Municipal Tax Incentives for Real Estate Projects and the Inflation Reduction Act
Sullivan & Worcester, Boston, MA (November 17, 2022) - State and Local Actions and Reactions to Covid-19
COST's 53rd Annual Meeting - Orlando, Florida (October 25, 2022) - Structuring OZ Projects: Best Strategies to Attract OZ Investment in Your Capital Stock, Select the Most Profitable Location and Time to Launch Your Development
Opportunity Zone Expo Arizona (October 3, 2022) - Understanding the Legal Framework and Tax Incentives
Opportunity Zones Forum 2022 (September 22, 2022) - Massachusetts Tax Residency . . . It’s Not Easy Come, Easy Go
Boston Estate Planning Council Educational Seminar (September 21, 2022) - QOF Talk: Structuring and Operating Strategies
Novogradac's 2021 Fall Conference, Cleveland, OH (October 21, 2021) - 2021 Opportunity Zone Expo
Denver, Colorado (July 15, 2021) - The OZ Act After COVID-19: Where We Go From Here
Virtual Program (May 19, 2020) - Opportunity Zone Updates
Massachusetts Society of CPAs (MSCPA) (July 16, 2019) - Opportunity Zones
Massachusetts Society of CPAs (MSCPA) (June 20, 2019) - New Orleans Investment Summit
New Orleans Business Alliance (June 13, 2019) - North Atlantic Regional State Tax Seminar
Council on State Taxation (May 9, 2019) - QOZs: The changing landscape for deal-makers
RSM (March 28, 2019) - Opportunity Zones: Where Are We After A Year?
Boston Bar Association (January 22, 2019) - Worcester's Opportunity Zones
Worcester Regional Chamber of Commerce (January 9, 2019) - Opportunity Zones: An Overview of the Latest Tax Incentive for Investors
Sullivan & Worcester and Pickwick Capital Partners (January 7, 2019) - Webinar Replay: Qualified Opportunity Funds
Gemini (December 5, 2018) - Securing Massachusetts and Local Tax Incentives to Maximize Opportunity Zone Benefits for Developers and Investors
Sullivan & Worcester Conference Center, Boston, MA (November 29, 2018) - The Land of OZ Explained – Understanding the New Opportunity Zone Proposed Regulations
Sullivan & Worcester Conference Center (November 8, 2018) - Opportunity Zones Presentation to MSCPA Tax Committee
Massachusetts Society of CPAs (June 19, 2018) - State Tax Appeal Protests and Procedures — The Dos and Don'ts
North Atlantic Regional State Tax Seminar (May 16, 2018) - The 11th Annual Worldwide Tax Update
Sullivan & Worcester Conference Center (May 15, 2018) - Representing Taxpayers Before the IRS and DOR
Sullivan & Worcester, One Post Office Square, 21st floor, Boston, MA (May 24, 2017) - Domicile and Residency Issues for Individuals and Estates - Planning, Audits and Appeals
Sheraton, Framingham, MA (January 17, 2017)