Cullen, Dan

Daniel F. Cullen

Baker & McKenzie LLP


Daniel Cullen has nearly 20 years of experience in tax planning for structured real estate transactions and related securities law matters. Mr. Cullen serves as a REIT columnist for the Journal of Passthrough Entities and is viewed as a leading professional in the taxation of REITs and related structures. Mr. Cullen received the Best Panel Award, for the presentation "An In-Depth Look at DSTs" at the 2013 ADISA Annual Conference. Mr. Cullen also serves as an adjunct professor at Northwestern University School of Law and DePaul University College of Law, teaching the Taxation of Structured Real Estate Transactions.

Practice Focus

Mr. Cullen has experience in all aspects of tax planning for inbound and outbound real estate projects, including real estate investment funds, leveraged partnerships, joint ventures, QOZ funds, REITs and Section 1031 Structures such as tenancy-in-common arrangements and Delaware Statutory Trust (DST) offerings. In addition, he handles tax matters related to lease financings of real estate, aircraft, railcars, school buses, cell towers and other telecommunications equipment, synthetic lease structures and the related tax aspects of derivatives and financial products. Throughout his career, Mr. Cullen has also been involved in tax planning for many domestic and international partnerships, joint ventures and emerging companies, including projects in Australia, China, Brazil, Mexico, Europe, Russia, the Bahamas, Panama and the Philippines. 

Representative Legal Matters

Prior to joining Baker McKenzie, Daniel Cullen acted on the following matters:

  • Acted as special tax counsel to Griffin Capital, as external advisor, in connection with Northstar Realty Finance Corp.’s acquisition of Griffin-America Healthcare REIT II, Inc. for approximately USD4 billion in cash and stock.
  • Acted as special tax counsel to AT&T Inc. (NYSE: T) in pre-paid master lease transaction of 9,100 cell towers to public REIT operator, Crown Castle International Corp., for USD4.85 billion.
  • Counseled Griffin Capital in connection with DST equity private placement and CMBS debt financing for commercial real estate, coupled with Up-REIT call option component and PILOT structure for local property tax purposes.
  • Counseled a major Boston real estate fund in connection with private REIT-blocker structure.
  • Counseled a major Chicago private capital company in connection with numerous DST structures and offerings.
  • Tax Counsel to Communications Sales and Leasing, Inc. (Nasdaq: CSAL), an independent publicly traded REIT, in a tax-free spinoff of select telecommunications network assets from Windstream Holdings Inc. (Nasdaq: WIN).

Professional Associations and Memberships

  • Alternative & Direct Investment Securities Association (ADISA) - Vice-Chair, Legislative & Regulatory Committee
  • American Bar Association - Member, Section on Taxation and Real Estate
  • Chicago Bar Association - Past Chairman, Federal Tax Committee Partnerships and Pass-through Entities Division
  • Institute for Portfolio Alternatives (IPA) - Board of Directors
  • National Association of Real Estate Investment Trusts (NAREIT) - Member


  • New York~United States (2013)
  • U.S. Court of Federal Claims~United States (2000)
  • U.S. Tax Court~United States (2000)
  • Illinois~United States (2000)
  • U.S. Court of International Trade~United States (2000)
  • Ohio~United States (1998)


  • New York University School of Law (LL.M. Taxation) (1998)
  • American University, Washington College of Law (J.D. cum laude) (1997)
  • State University of New York (B.A. magna cum laude) (1994)


  • English


Co-author, "Real Estate Investment Trust Corner," Journal of Passthrough Entitites, January-February 2019

Co-author, "UPREITs: Vertical Slice Guaranty Agreements," Journal of Passthrough Entities, September-October 2017


Moderator, "Establishing a QOZ Fund - Impacts and Considerations," Institute for Portfolio Alternatives - Leading the Conversation, IPA Forum, 12 February 2019

Panelist, “Hot Topics in Subchapter K and Structured Finance,” Tax Planning for the Remainder of 2017 and Beyond, Minneapolis, September 2017

Panelist, "Section 1031/DST Update," Alternative and Direct Investment Securities Association (ADISA) 2016 Annual Meeting, 2016