Daniel C. Lorenzen

Partner
Daniel Lorenzen

Daniel Lorenzen plans for wealth transfers to charities, family members, and future generations in practical, tax-efficient ways. Daniel’s practice includes individuals, families, and closely held businesses that have contacts in California, the United States, and around the world. He advises clients on all of the traditional tools of wealth planning, with an eye for holistic planning to minimize federal, international, state, and local taxes. Daniel uses these tools in service of clients’ desires to live happy and productive lives, to support charitable activities, and to raise capable and responsible children.

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 also advises clients in the crypto space, including investors in and founders of blockchain technologies, and is an advocate for evolution in the tax law to accommodate the evolving transactional capabilities of blockchain technologies.

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.

Dan 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, defending trustees’ conduct, and interpreting 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.

Daniel is fluent in Japanese and advises clients with Japanese and other cross-border contacts on tax and estate planning matters. He has advised Japanese companies on their U.S. transactions, including mergers and acquisitions in the United States.

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
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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

  • Member, Planning Committee, Estate and Trust Planning Conference, California Society of Certified Public Accountants
  • Member, Planning Committee, US-Japan Tax Alliance, Hawaii Tax Institute
  • Former co-chair, Planned Giving Council of California State University, Channel Islands
  • Member, Japan America Society of Southern California

Languages

  • Japanese

Recognition
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  • The Best Lawyers in America, Trusts and Estates, 2023