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Altman, Daniel Z.

Dr. Daniel Z. Altman

合伙人律师
  • 税务

Biography

DANIEL ALTMAN represents clients with respect to all tax aspects of domestic and cross-border M&A and corporate restructuring transactions, including tax free and taxable transactions, stock and asset sales, mergers, bankruptcy restructuring, spin-offs, recapitalizations, joint ventures, inbound and outbound investments, and IP structuring and utilization. He provides tax advice in a variety of fields, including life insurance, property and casualty insurance, IP, healthcare, real estate, manufacturing, services, asset management, and others. Dan also advises clients on all international aspects of U.S. federal income taxation and assists clients in their international tax planning.

Dan was recommended in Tax: International Tax in Legal 500 US 2017 and recognized as a “Next Generation Lawyer” in Tax Directors Handbook 2018. Dan was also recognized by Opportunity Zone Magazine in its 2019–2021 “Top 25 Opportunity Zone Influencers” list. Most recently, Dan was recognized in Who’s Who Legal 2024 as a leading lawyer for Corporate Tax.

Dan received his doctoral degree from Harvard Law School and, in addition to other publications, has published a book on Dispute Resolution under Tax Treaties in 2006 and authored the Bloomberg BNA Portfolio on dual consolidated losses in 2018. In 2006, Dan received the prestigious Mitchell B. Carroll Prize from the International Fiscal Association for his dissertation on the resolution of international tax disputes.

Experience

Representative Matters

Among his deals, Dan has represented:

  • Garage Beer, the fastest growing, independent beer brand in the U.S., in its strategic growth investment from Durational Capital Management.
  • WhiteHawk Capital Partners in connection with providing financing to newly formed acquisition vehicles of Brigade Capital Management, LP and Macellum Capital Management, LLC.
  • Brigade, Anchorage, and Beach Point Capital as ad hoc group of senior noteholders in a transaction support agreement and debt exchange offering for Finance of America, Inc. in which approximately US$342 million of existing senior secured notes were exchanged for new senior and exchangeable notes.
  • MPEG LA as special tax counsel in its merger with Via Licensing, a subsidiary of Dolby.
  • Apollo in respect to a US$1.25 billion financing to R.R. Donnelley & Sons Company. Apollo served as lead left arranger and administrative agent in the syndicated senior secured Term Loan B transaction.
  • Bridgepoint Group PLC in its investment in Blume Global, a provider of supply chain execution and visibility technology empowered by the largest globally connected multi-modal logistics network.
  • Sirius International Insurance Group in its strategic merger with Third Point Reinsurance, creating a US$3.3 billion company.
  • Goldman Sachs Urban Investment Group as lender and opportunity zone equity investor for the development of a mixed-use project that will house the National Urban League’s new headquarters in Harlem, New York City.
  • OrbiMed as the lead investor in a US$70 million private placement by Mereo BioPharma Group plc.
  • Aprea Therapeutics, Inc. in its US$98 million initial public offering of common stock.
  • Sirius International Insurance Group in its merger with Easterly Acquisition Corp., which resulted in a combined publicly traded company with a market capitalization of approximately US$2.2 billion.
  • American International Group in the multi-billion dollar sale of its legacy life settlements portfolio to leading alternative investment management firms.
  • Sirius International Insurance Group in the acquisition of International Medical Group.
  • Sirius International Insurance Group in the acquisition of ArmadaCorp Capital.
  • Harvest Partners and its portfolio company EyeCare Services Partners, a vertically integrated ophthalmologic services platform in numerous acquisitions of clinics and practices.
  • Siris Capital Group, LLC acquisition of Premier Global Services, Inc. for US$1 billion.
  • Nomura acquisition of minority shares American Century Companies, Inc. (a Mutual Fund Manager) for approximately US$1 billion.
  • Siris Capital Group, LLC acquisition of Polycom, Inc. for US$2 billion.
  • Kimmeridge Energy sale of Arris Petroleum Corp and other related assets to PDC Energy Inc. for US$1.5 billion.
  • OMERS Private Equity Inc., in partnership with existing physician owners, acquisition of Forefront Dermatology.
     

Community Involvement

Membership & Activities

  • Advisory Board Member, Opportunity Zones Section, Novogradac Journal of Tax Credits
  • Bloomberg BNA — Member of the U.S. International Advisory Board
  • Member of the New York State Bar Association  
  • Member of the United States Tax Court
  • 2017-2022, Member, Executive Committee of the Tax Section and Co-Chair, Committee on Corporations, Tax Section, New York State Bar Association
  • Former member of the Israel Bar Association

Credentials

Admissions & Certifications
  • U.S. Tax Court
  • 美国纽约州
Education
  • 美国哈佛大学法学院, S.J.D. (Doctor of Juridical Science/equivalent to a Ph.D. in law), 2005
  • Bar-Ilan University, 法学硕士, 1999, summa cum laude
  • Bar-Ilan University, 法学学士和文学学士, 1999, magna cum laude
Languages
  • Hebrew

News & Insights

  • Author, “Senate Reconciliation Bill Would Make Opportunity Zone Tax Incentive Permanent, Includes Other Significant Changes,” Sidley Update, June 18, 2025.
  • “New Private Letter Ruling Provides Important Guidance on the Opportunity Zone Rules but Also Adds Some Ambiguity,” Novogradac Journal of Tax Credits, April 2023.
  • “Avoiding the Pitfalls In Opportunity Zone Investments,” Novogradac Journal of Tax Credits, April 2021.
  • “In Much-Awaited Move, U.S. Treasury Removes United Arab Emirates From List of Boycotting Countries,” Sidley UpdateApril 14, 2021. 
  • “Common US Tax Considerations for Bankruptcy & Restructuring During an Economic Downturn,” Thomson Reuters, April 2020; Republished by Practical Law Journal, Fall 2020.
  • “UAE Ends Participation in Arab League’s Boycott of Israel; How to Understand Continuing U.S. Antiboycott Obligations,” Sidley Update, September 2, 2020.
  • Quoted in, “Treasury Plans to Clarify O-Zone Safe Harbor Requirements,” Tax Analysts, Tax Notes Today, June 6, 2019.
  • “IRS and Treasury Issue Second Set of Proposed Regulations on Opportunity Zone Tax Incentives,” Sidley Update, April 19, 2019. 
  • “Proposed Regulations Provide Important Guidance on the Tax Incentives for Capital Gain Invested in Opportunity Zones,” Sidley Update, October 23, 2018. 
  • “First Set of Proposed Regulations Released On GILTI,” Sidley Update, October 9, 2018.
  • “IRS Removes Debt Documentation Regulations,” Sidley Update, September 21, 2018.
  • “IRS Issues Interim Partial Relief From the Withholding Tax Obligations on Transfers of Partnership Interests,” Sidley Update, April 3, 2018.
  • New York State Bar Association, Tax Section, Report on Notice 2016-73 (Rep. No. 1377) (Submitted to the Department of the Treasury and the Internal Revenue Service on August 9, 2017). 
  • “IRS Delays Effective Date of the Intercompany Debt Documentation Rules,” Sidley Update, July 28, 2017.
  • “IRS Issues Proposed Regulations on New Tax Audit Rules for Partnerships,” Sidley Update, June 14, 2017.
  • “Final Debt-Equity Tax Regulations Significantly Narrow the Scope of the Proposed Regulations,” Sidley Update, October 17, 2016.
  • “The Scope of the DCL Regulations,” Bloomberg BNA: Tax Management International Journal, September 9, 2016.
  • “IRS Changes Its No-Ruling Policy on Tax-Free Spinoffs,” Sidley Update, August 26, 2016.
  • “Treasury and IRS Issue Significant New Guidance on Tax-Free Spinoffs,” Sidley Update, July 19, 2016.
  • “Tax Treatment for Discharge of Debt of Disregarded Entities and Grantor Trusts Clarified,” Sidley Update, June 10, 2016.
  • “Treasury and IRS Propose New Debt/Equity Regulations: Significant for Tax Structures Involving Related Party Debt,” Sidley Update, April 11, 2016.
  • “New Inversion Regulations Implement and Expand the Scope of the Anti-Inversion Tax Rules,” Sidley Update, April 7, 2016.
  • “Treasury and IRS Issue New Guidance Further Restricting the Tax Benefits of Inversions,” Sidley Update, November 23, 2015.
  • “New Partnership Tax Audit Rules Will Affect M&A Transactions Involving Partnerships,” Sidley Update, November 2, 2015.

BOOKS

  • Bloomberg BNA Portfolio — 6650 T.M., Dual Consolidated Losses, July 2018.
  • “Dispute Resolution under Tax Treaties,” IBFD, May 2006.