Daniel W. Hudson

Baker & McKenzie LLP


Daniel Hudson — a member of the Firm’s Tax Practice Group in Miami — practices mainly in the areas of international tax planning for multinational entities and high net worth individuals. He has authored several publications for Tax News and Developments and has spoken at Firm-sponsored trainings and conferences on tax issues. Active in the Firm’s pro bono activities, Daniel spearheads Baker McKenzie’s annual visit to the Camillus House Soup Kitchen, where the Firm serves dinner to hundreds of homeless and economically disadvantaged individuals.

Practice Focus

Daniel focuses his practice on helping clients address myriad international tax issues. He routinely conducts comprehensive analysis of changes within the areas of inbound US real estate structuring, reorganizing existing entities into more tax efficient structures, estate and trust planning and implementation for non-resident aliens, exit tax applications, voluntary disclosures, portfolio debt structuring and other sophisticated cross-border tax issues. Daniel has likewise addressed an array of tax issues in the domestic area, including deductibility of conservation easement donations and valuation discount applications.

Professional Associations and Memberships

  • Society of Trust and Estate Practitioners (STEP) - Member
  • Florida Bar - Tax Section
  • Greater Miami Tax Institute - Member
  • Florida International Bankers Association (FIBA) - Member


  • New York~United States (2011)
  • Florida~United States (2010)


  • New York University School of Law (LL.M. Taxation) (2007)
  • Hofstra University School of Law (J.D.) (2006)
  • Villanova University (B.S. Economics) (2002)


  • English

Previous Offices

  • Zurich


Co-presenter, "Navigating the Effectively Connected Income Tax Regime," Strafford Continuing Education Webinars, Miami, Florida, 23 March 2017

Co-presenter, "Moving to the United States: How to navigate obstacles in a world of devaluation and political uncertainty," Baker & McKenzie’s 17th Annual International Tax & Trust Training Program, Coral Gables, Florida, 27-28 October 2016

Co-presenter, "Foreign Investment in US Real Estate: The Two Tier Partnership (and beyond)," Baker & McKenzie’s 17th Annual International Tax & Trust Training Program, Coral Gables, Florida, 27-28 October 2016


Co-author, “Provisions Targeting “Base Erosion”: The BEAT and Other Deductions Limited Rules,” Baker & McKenzie North America Tax Practice Group Newsletter, February 2018

Co-author, “198 A Grecian Tragedy for the IRS: Tax Court Rejects Rev. Rule. 91-32,” Journal of Taxation, November 2017