Daniel C. Lorenzen
Daniel has significant experience advising general partners of private equity, venture capital, and other funds, and advising on the unique tax attributes and planning opportunities available to fund managers. Daniel represents business founders, and frequently advises on valuation opportunities and qualified small business stock opportunities for founders.
Daniel is fluent in Japanese and advises clients with Japanese and other cross-border contacts on tax and estate planning matters. For instance, he has advised on the application of Japanese inheritance taxes to U.S. assets, has assisted Japanese estates in qualifying for foreign estate treatment, and has implemented cross-border estate plans. He has advised Japanese companies on their U.S. transactions, including mergers and acquisitions in the United States.
Daniel is a frequent speaker on topics related to the jurisdictional aspects of a client’s personal residency and the residency of a client’s trust, estate, or business. For domestic and international clients, he implements trust structures in appropriate jurisdictions to maximize benefits relating to their tax and family wealth planning goals.
Daniel represents trustees, executors, and beneficiaries in the administration of trusts and estates, and litigates and settles disputes between trustees and beneficiaries. He has litigated throughout California and in the Surrogate's Court of Manhattan in New York. He has also resolved trust and probate litigation matters regarding the interpretation of instruments, defended trustees’ conduct, and interpreted tax allocation clauses, for example. He has prepared federal estate and gift tax returns and has represented fiduciaries before the Internal Revenue Service (IRS) in the audit and appeals process regarding valuation and other tax issues.
Related Practices
Experience
Representative Matters
- Advised Japanese residents on significant cross-border inheritance and estate planning matters
- Obtained favorable private letter rulings from the IRS related to incomplete gift trusts and generation-skipping transfer tax
- Negotiated with the Los Angeles County tax assessor's office to reverse a $20 million property tax reassessment
- Achieved a "no-change result" on a federal estate tax audit for issues related to annual exclusion gifts for partnership interests based on Price v. Commissioner
Insights
Credentials
Education
- J.D. University of Michigan Law School 2003
- B.S. Economics Brigham Young University 2000
Bar Admissions
- California
Court Admissions
- U.S. Tax Court
- U.S. District Court for the Eastern District of California
Professional Memberships and Activities
- Former member, Planning Committee, Estate and Trust Planning Conference, California Society of Certified Public Accountants
- Former co-chair, Planned Giving Council of California State University, Channel Islands
- Member, Japan America Society of Southern California
- Member, Trusts and Estates Section Executive Committee, California Lawyers Association
Languages
- Japanese
Recognition
- The Best Lawyers in America, Trusts and Estates, 2023 – 2024