Dan Rosen

Practice Areas

Daniel A. Rosen is a senior counsel in the North America Tax Practice Group in New York. He is a seasoned tax lawyer with over 16 years of experience with the Internal Revenue Service. Mr. Rosen was a key participant in the drafting of published guidance and administrative directives involving judicial doctrines for the IRS Large Business and International Division (LB&I). He served as IRS counsel in many cases that resulted in published opinions and is a frequent speaker for George Washington University School of Law, the Practicing Law Institute, Tax Executives Institute and the ABA. Additionally, Mr. Rosen served during law school as business editor of the Hofstra Law Review. He is an adjunct professor of law at New York Law School.

Mr. Rosen's practice focuses upon large case tax litigation and administrative tax controversies. He has been responsible for litigating some of the largest, most complex, and most sensitive cases pending before the United States Tax Court. He has litigated precedent-setting cases involving a wide variety of international and domestic tax issues, including transfer pricing, hybrid instruments, corporate and individual tax shelters, and research and development tax credits. He has worked closely with the US Department of Justice, Tax Division, on related cases and cross assignments, and has advised LB&I executives, managers and examiners on tax controversy matters, including settlement initiatives.

Mr. Rosen has broad experience representing clients under investigation by the US Congress, including the Permanent Subcommittee on Investigations. He assists clients during all phases of investigation, including responding to information and document requests, witness interviews, and hearings.

Publications

• Author, "The IRS’s Pincer Movement on Appeals Independence," Bloomberg BNA Daily Tax Report, 26 June 2017

• Author, “Chief Counsel’s Comments on Challenges to IRS Rulemaking,” Tax Notes, 4 July 2016

Expert in these Jurisdictions

USA

Languages Spoken

English

French

Education