Dan's legal practice focuses on federal tax and Title 31 matters including civil and criminal defense of IRS audits and investigations and civil tax litigation. Dan also assists taxpayers in navigating the process of coming into compliance, especially international taxpayers who have for one reason or another failed to comply fully with U.S. tax and Title 31 laws. Dan’s deep expertise concerning the IRS’ voluntary disclosure practice, the Streamlined Filing Compliance Procedures, and international penalty regimes allows him craft strategies to mitigate civil penalties and criminal exposure.
For over 19 years Dan served as an attorney for the Office of Chief Counsel of the Internal Revenue Service. Dan’s prior government service included extensive work in the arena of international enforcement and included assisting the IRS in completely revising the Voluntary Disclosure Practice. Dan also worked with the various Offshore Voluntary Disclosure Programs, the Streamlined Filing Compliance Procedures, foreign bank account reporting, Bank Secrecy Act investigations, various LB&I compliance campaigns, expatriation issues, international collection of taxes, and much more.
Dan received an undergraduate degree in accounting, summa cum laude, from the University of Texas at San Antonio, and a master’s degree in accounting from Trinity University. Dan received his J.D., with honors, from the University of Texas School of Law. While attending law school, he passed the Uniform CPA exam (not licensed as a CPA) and was a staff member on two law journals.