Daniel Johnson is a partner in the firm's State & Local Tax (SALT) Practice, where he works from Sacramento County, California, focusing on California tax controversy and counseling. Daniel represents businesses and individuals in disputes with the California Franchise Tax Board (FTB) and Office of Tax Appeals (OTA) at every stage of the controversy process, including audits, protests, settlement proceedings, administrative appeals, refund claims, and collection matters. Throughout his career, he has helped clients secure over $1 billion in tax and penalty savings by successfully resolving significant state tax disputes.
Clients regularly turn to Daniel for his counsel on California corporate franchise and income tax issues, including allocation and apportionment, market-based sourcing, alternative apportionment, business and nonbusiness income, financial institution rules, tax credits, withholding, and pass-through entity tax matters. His experience includes representing major financial institutions and other multistate businesses in significant California tax controversies involving complex factual, regulatory, and industry-specific issues.
Representing individuals in California residency and domicile matters, Daniel advises taxpayers and their professional advisors on establishing or changing residency, properly sourcing income following a move, and preparing for the increased scrutiny that can accompany significant income or liquidity events. When a residency determination is challenged, Daniel represents clients through the audit, protest, settlement, and appeal process.
His clients have included financial institutions, asset managers, health care organizations, real estate businesses, manufacturers, engineering and infrastructure companies, media and entertainment companies, tax-exempt organizations, entertainers, high-net-worth individuals, and other multistate businesses. In addition to handling high-stakes controversies, Daniel helps clients resolve practical tax-administration matters involving notices, estimated payments, withholding, refund claims, suspended entities, liens, levies, penalty abatements, and other collection issues. He has also advised clients on legislative and policy matters, including tax initiatives affecting the healthcare industry.
Prior to joining Hodgson Russ, Daniel spent more than a decade in PricewaterhouseCoopers LLP's National Tax Services State and Local Tax practice, where he handled complex California tax controversies, planning, and risk management matters. Earlier in his career, Daniel served as a judicial extern to Justice Joyce L. Kennard of the Supreme Court of California and worked in the Legal Department of the California State Board of Equalization.
