Daniel A. Rosen
Daniel A. Rosen focuses his practice on tax litigation before the US Tax Court and administrative tax controversies before the IRS. Dan assists clients on 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. Dan represents financial institutions, public companies, and government contractors under congressional investigation, guiding them throughout all phases of the investigation, including information requests and subpoenas, witness interviews, and hearings.
Before joining Morgan Lewis, Dan was a tax partner at another global law firm. Prior to his private legal practice, he served in multiple roles at the IRS’s Office of Chief Counsel for over 16 years, where he played a key part in the drafting of published guidance and administrative directives involving judicial doctrines and litigating precedent-setting cases. He also advised the agency’s Large Business & International Division executives, managers, and examiners on tax controversy matters, including settlement initiatives.
