State & Local Taxation (SALT)
Daniel Geraghty is an attorney in the Milwaukee office of Whyte Hirschboeck Dudek S.C. Mr. Geraghty focuses his practice on complex federal, international and state tax issues in both planning and controversy matters. Mr. Geraghty has represented numerous individuals, partnerships and corporations in a wide variety of matters in tax audits, administrative appeals and litigation. He is a leader of the firm's Federal Tax Controversy & Litigation Team. In addition to controversy matters, Mr. Geraghty has focused on complex business transactions including purchases, sales, mergers, divestitures and restructurings. As part of his focus on international tax matters, he has assisted numerous clients in structuring offshore activities whether through expansion or acquisition of existing businesses. He has also assisted numerous foreign businesses in structuring their U.S. activities.
Mr. Geraghty is also a Certified Public Accountant, having achieved a top score on the national CPA examination. Prior to practicing law, Mr. Geraghty worked as a Certified Public Accountant in a predecessor to one of the Big Four accounting firms.
- University of Wisconsin Law School, J.D., cum laude, Order of the Coif
- University of Wisconsin - Whitewater, B.B.A., summa cum laude
- State of Wisconsin, 1990
- United States Tax Court
- United States District for the Eastern District of Wisconsin
- United States Court of International Trade
- Represented numerous individuals and businesses involved in various stages of tax controversy matters, including both civil and criminal matters.
- Represented a number of taxpayers with the reporting of undisclosed foreign bank accounts. This includes both through the IRS offshore voluntary disclosure initiative and audit.
- Represented numerous clients in both acquiring existing operations in and/or expanding operations to foreign countries. He has completed multiple transactions in each of Canada, Mexico, Ireland, China, Australia, Japan, Brazil, India, the United Kingdom and France. The assistance included both corporate work as well as determining the optional tax structure from both a United States and foreign country perspective.
- Represented numerous foreign investors entering the United States, including structuring of inbound investment and negotiation of agreements with United States partners. A representative transaction is a German oil rerefinery entering the United States by partnering with an existing operation and then investing $50 million for a new rerefinery plant. Dan has also assisted several foreign investors in structuring acquisitions of real estate in the United States.
- Involved in the tax structuring and planning of many business acqusitions, ranging in size from $100,000 to $500 million.
- Previously served as legal counsel for a Fortune 500 company in completing business acquisitions. Lead corporate lawyer on all domestic and international business acquisitions for eight years ranging in size from $750,000 to $185 million.
- Represented numerous clients in tax deferred exchanges including a property exchange involving over 100 properties.
- Represented numerous individuals and entities in transferring real estate to real estate investment trusts, primarily public trusts.
- Involved in drafting numerous complex partnership agreements and operating agreements with both active members and equity investors.
- Assisted numerous clients in selling or donating conservative easements both through tax planning and working with various land trusts, ranging in size from several hundred thousand dollars to four million dollars.
- Assisted various medical professionals in structuring the sale or combination of their medical and dental practices. This includes determining the best tax structure, negotiating the acquisition or merger agreements and assisting with the ongoing employment relationships after closing.
- American Bar Association
- American Institute of Certified Public Accountants
- State Bar of Wisconsin
- Wisconsin Institute of Certified Public Accountants
- Milwaukee Tax Club
- Wisconsin State and Local Tax Club
- Glacial Lakes Conservancy, Inc., Board of Directors
Articles and Presentations
- Current Tax issues for Corporate Attorneys, presenter, Wisconsin Bar Association Annual Tax School, December 2010.
- Bankruptcy and Distressed Entities - Tax Considerations, presenter, WICPA Annual tax Conference, November 2009.
- Energy Tax Incentives, presenter, Wisconsin Bar Association 60th Annual Tax School, December 2009.
- Using Personal Goodwill to Reduce Taxes, author, On Balance (Magazine for Wisconsin CPAs), July/August 2006.
- Rewarding Your Good Deeds, author, On Balance (Magazine for Wisconsin CPAs), March/April 2005.