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Daniel Ryan

Daniel Ryan

Work Department

Tax

Position

Dan's practice focuses on representing taxpayers in federal and state tax litigation and controversies as well as transactional planning involving corporate, franchise, personal income and sales/use tax matters. Prior to his employment at Sullivan, Dan was an attorney at the Internal Revenue Service Office of Chief Counsel, where he represented the Internal Revenue Service in litigation before the United States Tax Court and served as a Special Assistant United States Attorney for the District of Massachusetts.

Dan is also one of the founders of the firm's Opportunity Zone practice group, and has assisted in the structuring of over $1 billion in Opportunity Zone projects throughout the country, including both real estate and operating business. Dan was named a Top 25 Tax Specialist by Opportunity Zone Magazine in 2022.

Dan is a frequent speaker on such matters as Opportunity Zone tax structuring, federal tax credits, federal and state controversy issues, and domicile planning. Dan has also been quoted on various tax matters in publications such as the Boston Globe, the Boston Herald, Law360, The Real Deal and Bloomberg Tax.

Dan has successfully represented clients under audit before the Internal Revenue Service and various state departments of revenue on a wide range of matters. For example, Dan successfully secured a multi-million dollar refund for an insurance company before the Massachusetts Supreme Judicial Court in Dental Service of Massachusetts v. Commissioner, a case of first impression in Massachusetts. Dan has also represented clients in domestic and offshore voluntary disclosures, and has successfully negotiated the abatement of federal tax penalties imposed based on various offshore tax issues.

Career

Bar & Court Admissions Massachusetts New York U.S. District Court, District of Massachusetts U.S. Tax Court

Memberships

Boston Bar Association, Tax Section American Bar Association, Tax Section

Education

Boston University School of Law (LL.M.) Taxation Catholic University, Columbus School of Law (J.D., magna cum laude) Boston College (B.A.)

Mentions

Tax • United States

US taxes: contentious