Daniel F. Carmody counsels clients on tax matters involving domestic and international transactions. In particular, his practice focuses on structuring partnerships, limited liability companies, and Subchapter S corporations. He also represents clients in audits and appeals before the Internal Revenue Service.
Prior to rejoining Morgan Lewis in 2020, Dan was managing director, M&A, Washington National Tax Services at PwC. Before that, he was of counsel at Morgan Lewis, having joined in 2012 after previously holding two positions in the Office of Chief Counsel for the IRS. He served in both the Large Business & International Division and the Passthroughs & Special Industries Division.
At the Large Business & International Division, Dan provided legal counsel related to the audits of large corporate taxpayers. This included substantive and procedural advice on issues such as transfer pricing and loss-generating transactions. He also provided support for the Global High Wealth Industry initiative, which takes an enterprise approach to the examination of high-wealth individuals and their associated entities.
As senior counsel in the Passthroughs & Special Industries Division, Dan addressed the taxation of partnerships, limited liability companies, and Subchapter S corporations. He also focused on the application of the passive activity loss rules and at-risk loss limitation provisions.
Dan has also served as an adjunct professor in the Graduate Tax Program at Villanova University Law School.
Villanova University School of Law, 1997, LL.M. (Tax)
Georgetown University Law Center, 1996, J.D.
Loyola College in Maryland, 1993, B.A.
US Tax Court
Awards and Affiliations
Recommended, Tax: US taxes: contentious, The Legal 500 US (2021)
Adjunct Professor, Graduate Tax Program, Villanova University Law School