Daniel F. Carmody is of counsel in Morgan Lewis's Tax Practice. Mr. Carmody provides counseling on tax matters involving domestic and international transactions, with a focus on structuring for partnerships, limited liability companies, and Subchapter S corporations. He also represents clients in audits and appeals before the Internal Revenue Service.

Prior to returning to Morgan Lewis, Mr. Carmody served in the Large Business & International Division of the Office of Chief Counsel for the Internal Revenue Service. In that position, he provided substantive and procedural legal advice related to the audits of large corporate taxpayers on issues such as transfer pricing and loss generating transactions. Mr. Carmody also provided support for the Global High Wealth initiative, which takes an enterprise approach to examinations of high wealth individuals and their associated entities.

Mr. Carmody also previously served as a senior counsel in the Passthroughs & Special Industries Division of the Office of Chief Counsel for the Internal Revenue Service, where he provided advice on the taxation of partnership, limited liability companies, and Subchapter S corporations as well as the application of the passive activity loss rules and at risk loss limitation provisions.

Mr. Carmody earned his LL.M. in tax from Villanova University School of Law in 1997 and his J.D. from Georgetown University Law Center in 1996. He earned his B.A. from Loyola College in Maryland in 1993.

Mr. Carmody is admitted to practice in Pennsylvania and before the U.S. Tax Court.