Daniel focuses on a broad range of federal income tax issues including cross-border transactions, capital market transactions, private and public mergers and acquisitions, private and public investments funds, financial restructuring, REITs, joint ventures, and tax controversies.

Daniel has a broad tax practice with a focus on tax considerations of private and public investment funds, private and public M&A transactions, real estate transactions, financial restructuring, and cross-border transactions. Additionally, Daniel has represented US and non-US high-net-worth individuals with respect to their US tax planning. Daniel’s experience, understanding of complex issues, financial skills, and thoroughness allow him to efficiently help resolve complex issues and guide clients toward the best tax results.

Daniel is active with the Florida bar and served as a chair of the Florida Bar Tax Certification Committee from 2020 to 2021.

Daniel’s pro-bono work includes representation of low-income individuals in front of the IRS and assistance to tax-exempt organizations.

Relevant Experience

• Advised on the tax aspects of the acquisition by Lindblad Expeditions Holdings of an 80% stake in Classic Journeys.
• Advised private investment fund sponsors on structuring fund that qualified for Qualified Opportunity Zone tax advantages.
• Advised the Individual Investor Group of a multinational investment bank on the tax aspects of structuring various private investment funds.
• Advised various private equity funds and companies on tax aspects of private equity investments and acquisitions.
• Advised the private real estate investment trust Carr Properties on the tax aspects of a $300 million convertible debt investment by Clal Insurance Enterprise Holdings Ltd.
• Advised on the tax aspects of a restructuring and an acquisition by a group of lenders of American Addiction Centers Inc.

• Advised on the tax aspects of a Chapter 11 restructuring and acquisition by certain lenders of Ultra Petroleum, a Denver-area oil and gas company.
• Advised an investment management company on the tax aspects of the acquisition of certain assets of a REIT in a sale process under Section 363 of the United States Bankruptcy Code. Advised on the tax aspects of the acquisition by Reagan Outdoor Advertising of over 5,200 displays across three metro markets from Fairway Outdoor Advertising.
• Advised on the tax aspects of $11 billion going private transaction by Ultimate Software (Nasdaq: ULTI).
• Advised on the tax aspects of the acquisition of McNeil & Company (a specialty insurance company) by Arch Capital Group Ltd.
• Advised on the tax aspects of the acquisition of the Davenport (a 232,400 square feet commercial building) in Cambridge, MA by Alony-Hetz
• Properties and Investments Ltd. and Oxford Property.
• Advised on the tax aspects and structuring of an acquisition by Alony-Hetz Properties and Investments Ltd. of an interest in two Boston, MA office buildings valued at approximately $390 million.
• Advised on restructuring of a multi-billion pension-held private real estate investment fund to accommodate co-investment by third parties.
• Analyzed and advised on a conversion of a real estate holding company into a REIT.
• Advised high-net-worth individuals on tax issues relating to their real estate holdings, cross-border transactions, 1031 exchanges, business separations, and succession planning.

Bar Admissions

Education
LLM, New York University School of Law, 2010JD, University of Michigan Law School, cum laude, Clarence Darrow Scholar, Associate/Contributing Editor, Michigan Law Review, 2006MBA, University of Louisville, with distinction, 2003BS, University of Louisville, summa cum laude, 2001

• Untangling the Constructive Ownership Rules for Foreign Entity Information Returns, Journal of Taxation
• New Procedures for ITINs Complicate Compliance with US Tax Obligations, Tax Notes International
• Reporting Interest of Foreign Depositors Irks Florida Bankers, Daily Business Review
• Changing Your Residency Can Save Taxes, but It’s Not for Everyone, Daily Business Review
• REIT Conversions, Practical Law: The Journal
• Impact of the Tax Reform Act on the Insurance Industry, AIRROC Matters
• Using Inconsistent Regs. as a Defense Against 5471 Information Reporting Penalties, Journal of International Taxation