Daniel Zukerman Email and Phone Number
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Daniel Zukerman, JD, LLM (Taxation) has broad domestic and international tax, transactions and controversy experience in private, public and government sectors. Daniel is a two-time recipient (2024-2025 and 2022-2023) of the prestigious Office of Chief Counsel Special Act Award (U.S. Department of Treasury) for Distinguished Performance and Exceptional Contributions. Daniel is currently a Senior Attorney at the IRS Office of Chief Counsel (Large Business & International Division) where he focuses on a wide spectrum of complex domestic and international corporate, partnership and pass-through tax matters and cross-border transactions. Daniel is a Big 4 alum where he concentrated on complex tax and business matters including the development, management and execution of multi-billion dollar inbound and outbound transactions, domestic and cross-border M&A, global structuring, controversy and other transactional & compliance matters to many of the world’s largest organizations, private companies, multinational corporations and Fortune 500 companies in all industry sectors.Daniel’s work experience includes lead attorney in a $4 Billion tax matter for a publicly traded corporation, $650 Million worthless stock deduction, assisting tax planning for a $2 Billion merger between two publicly traded companies, lead role in a $1 Billion acquisition including multi-country financing, debt push-down and integration, lead role in an $800 Million joint venture for a private equity partnership and lead role in a $450 Million acquisition and integration for a publicly traded corporation.Daniel received his LLM in Taxation from Northwestern University Pritzker School of Law, JD from Chicago-Kent College of Law (IIT), and Bachelors of Business Administration (BBA) from the School of Business at the University of Wisconsin-Madison. While at Northwestern, Daniel was on the 2010 National Law Review with his M&A legal article on the Janus Capital Cash-Rich Split-off.Publications/Speaking Engagements2021 - Present - IRS Chief Counsel Large Business & International Division CLE Distinguished Lecture Series2020 - Present - Dept. of Treasury Finance Practice Network - High Net Worth Group2019 - 2020 - Deloitte International Tax and M&A Training Seminar2017 - PwC Cross-Border IP Planning2016 - 2017 - PwC International Tax Academy 2012 - 2015 - EY Tax Academy1/6/2012 - The Wall Street Journal (M&A)2010 - National Law Review, Northwestern University Pritzker School of Law
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Senior Attorney | Irs Office Of Chief Counsel (Large Business And International Division)Internal Revenue ServiceChicago, Il, Us -
Senior Attorney | Irs Office Of Chief Counsel (Large Business & International Division)Internal Revenue Service Oct 2020 - PresentWashington, District Of Columbia, Us• Recipient, 2024-2025 Office of Chief Counsel, Large Business & International Division, Special Act Award for distinguished performance and exceptional contributions.• Recipient, 2022-2023 Office of Chief Counsel, Large Business & International Division, Special Act Award for distinguished performance and exceptional contributions.• Appointed as Counsel to the Large Partnership Cadre.• Specialize in international and domestic tax planning, advisory, controversy and litigation.• Work with Associate Chief Counsel Branch (Technical), Inflation Reduction Act (IRA), International Tax Policy, International Tax Planning, International Tax Advisory, BEPS, Foreign Tax Credits, GILTI, BEAT, FDII, FIRPTA, FATCA, FBAR.• Energy Credits (sections 45 and 48).• Lead complex cross-border and domestic transaction advisory, disputes and litigation for the IRS Office of Chief Counsel Large Business & International Division in Audits, Appeals, and U.S. Tax Court.• Advise, draft and review PLRs, TAMs, Closing Agreements.• Advise Appeals Division on complex cross-border and domestic transactions and international organizational structures.• Advise Special Counsel IRS Office of Chief Counsel Large Business & International Division on complex international, domestic, cryptocurrency and blockchain tax issues.• Selected for the Department of Treasury IRS Office of Chief Counsel Finance Practice Network - High Net Worth Group.• Selected for the IRS Office of Chief Counsel Litigation and Advisory Mentoring Program.• Selected for the IRS Office of Chief Counsel BFF Ambassador Program.• Leader of the IRS Office of Chief Counsel Large Business & International Division CLE Webinar Distinguished Lecture Series on International Technical Tax Matters.• Co-Leader of the IRS Office of Chief Counsel Large Business & International Division CLE Webinar Lecture Series on Summonses, Tax Litigation, Motions and Depositions.
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Senior Manager, International TaxDeloitte Feb 2019 - Sep 2020Worldwide, Oo• Provided integrated transaction tax, business, accounting and finance advice to Fortune 500 companies, private equity and other companies for a wide range of tax services and transactions in the U.S., Europe, Asia and other international markets.• Management, strategy, development, implementation of inbound and outbound transactions, domestic and cross-border mergers & acquisitions, dispositions, financing, debt planning, intercompany loan rationalization, capital structure planning, licensing arrangements, restructuring of international operations, planning involving the newly enacted Tax Cuts and Jobs Act (“TCJA”) and other transactional work in a variety of industries.• Advised on the tax implications of doing business in the U.S., including complex transactions involving foreign investment in U.S. real property, permanent establishment (PE) matters, effectively connected income (ECI) issues and tax treaties.• Advised on cash repatriation planning and strategy, withholding tax issues and IP matters for multinational businesses and investments.• Lead role in the management of large multinational corporation international tax compliance engagements, which included primary and secondary review of complex U.S. tax returns including Form 5471 for foreign corporations and Form 8858 for disregarded entities. -
International Tax ManagerPwc Jun 2016 - Feb 2019Gb• Provided integrated transaction tax, business, accounting and finance advice to Fortune 500 companies, private equity and other companies for a wide range of tax services and transactions in the U.S., Europe, Asia and other international markets.• Management, strategy, development, implementation of inbound and outbound transactions, domestic and cross-border mergers & acquisitions, dispositions, financing, debt planning, intercompany loan rationalization, capital structure planning, licensing arrangements, restructuring of international operations, planning involving the newly enacted Tax Cuts and Jobs Act (“TCJA”) and other transactional work in a variety of industries.• Lead role in a multi-phase design and implementation of a $450 Million acquisition by a publicly traded corporation along with the subsequent integration of a corporation with business operations in over 25 countries. • Lead role in an $800 Million joint venture between a private equity partnership and a publicly traded corporation. Lead role in the design, project management and implementation of the global structure for the joint venture including the formation of the new entities and the acquisitive transactions of the legacy foreign operations in multiple jurisdictions totaling over 40 countries transferred into the global structure. • Advised on the tax implications of doing business in the U.S., including complex transactions involving foreign investment in U.S. real property, permanent establishment (PE) matters, effectively connected income (ECI) issues and tax treaties.• Counseled on cash repatriation planning and strategy, withholding tax issues and IP matters for multinational businesses and investments.• Lead role in the management of large multinational corporation international tax compliance engagements, which included primary and secondary review of complex U.S. tax returns including Form 5471 for foreign corporations and Form 8858 for disregarded entities. -
Tax Counsel - M&A/International TaxGuggenheim Partners Jun 2015 - May 2016New York, New York, Us• Management, strategy, development, implementation and execution of multi-billion dollar inbound and outbound transactions, domestic and cross-border mergers & acquisitions, dispositions, financing, licensing arrangements, restructuring of international operations and other transactional work in a variety of industries.• Lead role in the management of large multinational partnership and corporation tax compliance engagements, including helping maintain compliance with U.S. and international tax laws and providing primary and secondary review of complex U.S. tax returns including Form 5471 for foreign corporations and Form 8858 for disregarded entities.• Advised on private equity and venture capital transactions at an early stage to evaluate the domestic and international tax and legal implications of such transactions.• Provided integrated tax, corporate, finance and legal planning advice for transactions in the U.S., Europe and other international markets.• Advised on international structures for conducting business globally and counsel on holding companies, foreign representative offices, branches, subsidiaries, tax treaties, foreign tax credits and all other facets of outbound business and investment.• Counseled on cash repatriation planning and strategy and withholding tax issues for multinational businesses and investments.• Advised on the tax implications of doing business in the U.S., including complex transactions involving foreign investment in U.S. real property, permanent establishment (PE) matters, effectively connected income (ECI) issues and tax treaties.• Counseled on the tax aspects of debt, equity and hybrid securities offerings, leveraged financing, investment fund formations, U.S. and non-U.S. financial instruments and other capital markets transactions and assess both the tax consequences and risks of new financial product structures.• International Tax Advisory Committee, 2015-2016• Finance Peer Committee, 2015-2016 -
International Tax ServicesEy Jun 2011 - Jun 2015London, Gb• Assisted with a $2 Billion merger involving a multi-billion dollar publicly traded company. Advised on the U.S. tax consequences and managed the coordination of the international tax consequences involving 27 countries. • Assisted with a $100 Million transaction involving debt planning for a multi-country contribution, distribution and liquidation. • Assisted with a $900 Million transaction for a multi-billion dollar publicly traded company. Advised on issues including dividends, subpart F income, section 954(c)(6) look-through exception, and foreign tax credit.• Assisted with a $200 Million Canadian restructuring for a multi-billion German based multinational corporation. Advised on the U.S. tax consequences of the restructuring, drafted the restructuring step plan, and managed the coordination of the Canadian and German tax consequences.• Assisted with a wide range of tax services for a U.S. based multinational confectionary, food and beverage conglomerate with annual sales of $36 Billion and operations in more than 80 countries.• Advised on the tax implications of doing business in the U.S., including complex transactions involving foreign investment in U.S. real property, permanent establishment and effectively connected income issues, and tax treaties.• Assisted in international tax reviews for the year-end audits of Fortune 500 companies. • Advised on cash repatriation planning and withholding tax issues for multinational Fortune 500 companies.• Lead role in the management of large multinational corporation international tax compliance engagements, which included primary and secondary review of complex U.S. tax returns including Form 5471 for foreign corporations and Form 8858 for disregarded entities.• Mentored Ernst & Young Senior Associates & Staff and provided leadership, counseling and career guidance. -
Candidate, Master Of Laws (Llm) Taxation - AttorneyNorthwestern University School Of Law 2010 - 2011Chicago, Il, Us -
Attorney, Revenue Litigation Division, Department Of LawCity Of Chicago 2008 - 2010Us• Researched law and assisted with on-going property and state and local tax matters.• Researched compliance issues and drafted related motions regarding various litigation issues, including penalties, regulatory, enforcement and other tax-related matters.• Assisted with government administration, regulatory, and compliance legal services.• Assisted with various litigation matters and represented the City of Chicago in circuit court and administrative hearings; prepared and presented oral reports to circuit court judges and administrative hearings officers.• Developed and managed law clerks and provided leadership, counseling and guidance. -
Contract AttorneyKirkland & Ellis Llp 2007 - 2008Chicago, Illinois, Us• Contract Attorney• Assisted with a wide range of litigation support including review of documents and review management technologies for on-going litigation matters. -
Tax Attorney Volunteer - Volunteer Income Tax Assistance Program (Vita)Ladder Up 2006 - 2008• Provided legal counsel and guidance to low-income individuals on a variety of tax-related issues.• Assisted with preparation and review of U.S. tax returns and helped individuals identify and address tax issues to maximize earnings and savings.
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Law Clerk, Commercial Real Estate GroupAlsj, Inc. May 2005 - Aug 2005• Assisted in a wide variety of on-going real estate, tax and secured lending issues.• Reviewed real estate-related documents and participated in meetings for the acquisition and disposition of real estate properties. • Conducted legal research and assisted with legal counsel and guidance.
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Law Clerk, Municipal Litigation Division, Civil Actions BureauCook County State'S Attorney'S Office May 2004 - Aug 2004Us• Conducted legal research for several practice areas; drafted technical memos and briefs.• Assisted with depositions, witness preparation, briefing, settlement negotiations and trial.• Worked closely with Assistant State Attorney Donna Lach as legal defense counsel for David Orr, County Clerk.
Daniel Zukerman Skills
Daniel Zukerman Education Details
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Northwestern University Pritzker School Of LawTaxation -
Northwestern University - Kellogg School Of ManagementTaxation
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Chicago-Kent College Of Law, Illinois Institute Of TechnologyLaw
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Wisconsin School Of BusinessGeneral
Frequently Asked Questions about Daniel Zukerman
What company does Daniel Zukerman work for?
Daniel Zukerman works for Internal Revenue Service
What is Daniel Zukerman's role at the current company?
Daniel Zukerman's current role is Senior Attorney | IRS Office of Chief Counsel (Large Business and International Division).
What is Daniel Zukerman's email address?
Daniel Zukerman's email address is dz****@****tte.com
What is Daniel Zukerman's direct phone number?
Daniel Zukerman's direct phone number is +131282*****
What schools did Daniel Zukerman attend?
Daniel Zukerman attended Northwestern University Pritzker School Of Law, Northwestern University - Kellogg School Of Management, Chicago-Kent College Of Law, Illinois Institute Of Technology, Wisconsin School Of Business.
What skills is Daniel Zukerman known for?
Daniel Zukerman has skills like International Tax, Mergers And Acquisitions, Legal Research, Corporate Tax, Corporate Law, Litigation, Legal Writing, Business Advisory, Tax, Restructuring, Partnership Taxation, Mergers.
Who are Daniel Zukerman's colleagues?
Daniel Zukerman's colleagues are Trevon Cunningham, Jalitza Matos, Mba, Rita Gayle, Lucresia Parks, David Laman, Barbara Wynn, Jack Ranallo.
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