Daniel N Price

Daniel N. Price (“Dan”) represents high-net-worth individuals, authors, musicians, international families, fiduciaries, family offices, and businesses in complex federal tax controversies and cross-border tax matters. His practice focuses on IRS examinations and appeals, Tax Court litigation, international information-reporting and penalty matters, expatriation, tax treaty issues, voluntary disclosures, and sensitive private-client matters involving foreign trusts, pensions, investments, insurance, and more. Dan also advises on defending IRS audits of Puerto Rico bona fide residents. Dan leverages his extensive prior government experience as an attorney and manager with the Office of Chief Counsel of the Internal Revenue Service to assist his clients. Dan’s IRS experience in the IRS’ voluntary disclosure practice, the Streamlined Filing Compliance Procedures, and international penalty regimes allows him craft strategies to mitigate civil penalties and criminal exposure.

American College of Tax Counsel

Society of Trust and Estate Practitioners

American Bar Association, Section of Taxation

Recent publications include:

“Foreign Insurance Excise Tax: Issues for Individual Clients and a Policy Proposal for the IRS,” TAX NOTES FEDERAL (July 6, 2026) (co-authored with Michael E. Romero)

“Broken Promises and Procedures: Systemic Penalties Persist for Late Forms 3520,” TAX NOTES FEDERAL (Feb. 11, 2026)

“Proposed Voluntary Disclosure Practice Changes Need More Specificity,” TAX NOTES FEDERAL (Feb. 6, 2026) (co-authored with Caroline D. Ciraolo)

“Relief Procedures for Certain Former Citizens: Underused and Needing Expansion,” TAX NOTES FEDERAL (Jan. 30, 2026)

“A Guide to Best Practices for Blocked Foreign Income Reporting,” TAX NOTES FEDERAL (Nov. 27, 2025)

“Is the IRS Trying to Terminate the Voluntary Disclosure Practice?” TAX NOTES FEDERAL (Nov. 25, 2024)

“Modifying VDP FBAR Penalties Will Promote Voluntary Compliance.” TAX NOTES FEDERAL (June 12, 2023)

Dan’s clients have included entrepreneurs, executives, investors, early crypto adopters, expatriates, family offices, inventors, a best-selling author, globally known musicians, and many U.S. citizens residing abroad.

Representative Matters:

• Represented a high-net-worth taxpayer in an IRS examination. Audit resulted in a net refund to client.

• Represented corporation in an IRS LB&I examination. Audit was closed with immaterial change with no tax due.

• Obtained complete abatement of penalties asserted under §§ 6038, 6038D, 6039F, and 6677 in numerous cases.

• Advised a U.S. citizen residing abroad concerning expatriation, prior-year compliance, and potential covered-expatriate status.

• Advised former U.S. citizen on § 2801 and gifting issues to U.S. citizen children

• Assisted many U.S. citizens residing abroad in rectifying international reporting issues without any IRS penalty assessments.

• Represented home builder in United States Tax Court in dispute with IRS over an accounting method. Case settled with IRS conceding dominant issue.

• Represented partnership in United States Tax Court in dispute with IRS concerning significant penalties for late § 1146 partnership withholding. IRS conceded all penalties.