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Chris McLoon discusses how taxpayers can qualify for increased renewable energy tax credits following the IRS' recent notice.
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The Cozen O’Connor Tax Practice has been providing sound advice to clients for decades. We serve public and private companies, joint ventures, real estate interests, high net worth individuals, and exempt organizations.
In both our U.S. federal and Canadian federal tax practices, we advise clients on the tax implications of mergers and acquisitions, financings, real estate deals, entity structure, contractual arrangements, cross-border transactions, and other business arrangements. In our U.S. state and local tax practice, we provide the full range of transactional counsel and represent clients in tax controversies and litigation. Our Canadian federal tax practice has significant experience in advising on tax matters related to the mining industry. On occasion, the U.S. state and local tax team also supports client efforts to reform state and local tax statutes or regulations.
Tax is a key element of Cozen O’Connor’s transactional practice. Our tax group collaborates closely with colleagues from corporate law, capital markets, real estate, public and project finance, private client services, health law, labor and employment, and mergers and acquisitions on a full range of business matters. The firm’s culture of cross-disciplinary cooperation benefits clients enormously. Our tax advisors are involved from the start to ensure that every project is structured and carried out to achieve tax efficiency.
Cozen O’Connor’s tax lawyers provide support at inception and throughout the entire life cycle of a deal. For pure transactional lawyers, work is done at closing. But our tax attorneys provide tactical advice for as long as a business decision has tax implications, which can be several years or several decades. Having continuous tax counsel is essential because our attorneys accrue invaluable institutional knowledge over time. They learn the hot-button issues and logic of prior decisions to quickly assess how future changes will affect a client’s tax position.
Because every tax matter is inherently case-specific and subject to interpretation, Cozen O’Connor attorneys carefully avoid generic solutions and reject a this-is-how-it’s-always-done mentality. For analytical purposes, we often calculate the cost of following a standard model. But that figure simply represents an opening bid. We then undertake to lawfully improve on that baseline by adding nuance and creativity. Through innovation, we are often able to reduce tax costs considerably.
An essential aspect of a strong tax practice is good communication. Because few people other than tax lawyers are fully fluent in code-speak, a good tax attorney must be able to translate the tax code into plain English, focus on core issues, and present information to clients in a manner that is at once sophisticated and comprehensible. Cozen O’Connor attorneys can operate at a high level using a common lexicon and are known for their candor and lack of pretense.
SERVICES
Mergers, Acquisitions, and Business Transactions
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Advise clients on the tax aspects of public and private mergers, acquisitions, buyouts, and joint ventures, as well as spin-offs, liquidations, and other divestitures
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Counsel clients on structured finance, project finance, leasing transactions, and the use of derivatives to hedge business operations and debt issuances
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Advise clients on appropriate business structure, including general and limited partnerships, limited liability and series limited liability companies, Canadian unlimited liability companies, and business trusts
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Provide tax planning prior to incorporation or securities offerings
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Guide the organization and syndication of private equity funds
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Structure cross-border transactions with the goal of minimizing U.S. and Canadian federal income tax consequences
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Advise clients on corporate tax issues related to the use of exchangeable shares and the distribution of assets to shareholders
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Provide guidance on Canadian flow-through limited partnership offerings
Real Estate
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Advise clients on the optimal structure for real estate investments
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Represent public real estate investment trusts in the entire gamut of tax matters, including the management of REIT income and asset tests and formation of non-publicly traded REITS
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Counsel clients regarding securitizations, including real estate mortgage investment conduits (REMICs) and other asset securitizations
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Advise clients with real estate investments that qualify for safe harbor protection
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Assist with tax-free exchanges of like-minded properties
Tax-Exempt Organizations
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Serve public charities, museums, trade associations, health care providers, veterans’ organizations, and private foundations
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Advise on the formation of non-profit corporations and charitable trusts
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Obtain tax rulings and federal, state, and local tax exemptions
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Counsel high net worth individuals and businesses on the advantages of establishing and operating private foundations
U.S. State and Local Tax
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Represent clients in state and local tax controversies and litigation
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Advocate for legislative and regulatory changes in state and local tax codes
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Advise clients about variations in state tax laws and perform multi-state tax analyses
Tax Compliance, Controversy, and Litigation
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Render formal tax opinions in connection with specific transactions and obtain rulings from the Internal Revenue Service and state and local tax authorities
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Represent clients in connection with IRS tax examinations, including before the IRS appeals branch, and in litigation before state and local taxing authorities, the U.S. Tax Court, and the federal district and appeals courts
TEAM
Cozen O’Connor’s Tax Practice is made up of exceptionally qualified practitioners, including a former chief counsel to the Pennsylvania Department of Revenue. Several attorneys are certified public accountants and have master’s degrees in taxation law. Our most seasoned attorneys are leading scholars in the field and have authored or edited widely referenced treatises on state tax law and real estate tax.
The firm differentiates itself, in part, through its staffing model. In plain terms, we do not believe clients are best served by sprawling teams of undermanaged associates. While we have the capacity to add support as necessary, at Cozen O’Connor tax matters are primarily handled by experienced tax professionals who are deeply knowledgeable about the relevant subject area and have credibility with judges and counterparts. Because veteran attorneys are fully cognizant of the details of every matter, they are prepared to engage in peer-to-peer dialogue with clients at any time. When clients call at 3 a.m., they don’t just get a response – they get an answer.
September 20, 2024
Christopher McLoon discussed preformation capital expenditure reimbursement in Tax Notes Federal, Volume 174.
September 18, 2024
Christopher McLoon discusses what PIP (partners interests in the partnership) allocations are and when and why they should be used.
September 04, 2024
Dan Schulder discusses the PA Commonwealth Court's ruling that Goodwill Industries is entitled to a real estate tax exemption and does not compete with commercial enterprises.
August 27, 2024
Christopher McLoon shares advice for businesses and their managers to avoid unintended tax consequences when forming a partnership.
July 23, 2024
Chris McLoon discusses the Prevailing Wage and Apprenticeship (PWA) regulations' key points.
July 15, 2024
Dan Schulder and Heidi Schwartz discuss the Pennsylvania Commonwealth Court's ruling that the exemption for transfers of real estate from a trust to a beneficiary for no or nominal consideration also applies to transfers of interests in real estate companies.
May 29, 2024
Chris McLoon discusses how taxpayers can qualify for increased renewable energy tax credits following the IRS' recent notice.
May 06, 2024
Richard Silpe and Nathan Rudy discuss the tax implications of the Department of Justice's proposal to reclassify marijuana from a Schedule I to a Schedule III controlled substance.
May 01, 2024
Chris McLoon discusses the U.S. Treasury's new rules for Real Estate Investment Trusts (REITs), which will affect how foreign investors are taxed.
January 10, 2024
Cheryl Upham and Heidi Schwartz discuss changes to the tax treatment of grantor trusts which will finally conform Pennsylvania's rules to federal tax law.
December 18, 2023
Christopher McLoon discusses a Tax Court ruling that a limited partner's share of income may be subject to self-employment tax.
November 27, 2023
Chris McLoon and Wendy Venoit discuss the Internal Revenue Service’s proposed regulations concerning energy tax credits.
August 31, 2023
In this article, Mark outlines ten examples of challenges, ranging from limiting bank qualifications for debt service savings, and handling arbitrage earnings and swap termination payments, to addressing private use of bond-financed property and managing bond-financed property.
May 31, 2023
New Jersey will automatically treat federal S corporations as New Jersey S corporations, effective for periods beginning on or after December 22, 2022.
October 17, 2022
Matthew Clyde co-authored the Bloomberg Tax Portfolio addressing the interplay of benefits and bankruptcy law.
September 20, 2022
The City of Philadelphia has extended the deadline for the filing of a first level review of real estate assessment appeals to October 14, 2022.
July 26, 2022
Pennsylvania’s 2022-2023 budget, Act of Jul. 8, 2022, implements sweeping tax reform and revises some of Pennsylvania’s most business-unfriendly tax provisions.
April 05, 2022
Joe Hill, Joe Bright, and Brianna Westbrooks discuss Councilmember Brooks' proposed tax on certain intangible property, including direct holdings in stocks and bonds, at 0.4 percent.
September 27, 2021
Nathan Rudy and Rich Silpe discuss the draft tax legislation that was released as part of the “Build Back Better” budget reconciliation program and how it may impact the Section 1202 gain exclusion on the sale of qualified small business stock in a C corporation.
January 27, 2021
Joe Bright and Heidi Schwartz provide an analysis of Autozone Development Corp.’s appeal of a property tax assessment that is pending before the Pennsylvania Supreme Court.
December 04, 2020
Heidi Schwartz and Joe Bright co-authored an article in Bloomberg Tax addressing the reporting challenges and potential tax bills confronting employers whose employees are working from home in jurisdictions outside of the employer’s workplace during the COVID-19 pandemic.
September 28, 2020
Tom Gallagher and Dennis Cohen are co-authors of an article published in the October 2020 issue of Pratt’s Journal of Bankruptcy Law.
September 17, 2020
Joe Bright and Heidi Schwartz co-authored an article published in Bloomberg Tax analyzing the Pennsylvania Commonwealth Court’s recent decision in Synthes USA HQ, Inc. v. Pennsylvania.
September 01, 2020
Thomas Gallagher and Dennis Cohen are co-authors of an article published in the Pratt’s Journal of Bankruptcy Law.
August 11, 2020
Joseph Bright and Bob Careless co-authored an article, published by Bloomberg Tax, analyzing a recent decision by the Commonwealth Court of Pennsylvania that is favorable to commercial taxpayers facing selective reverse assessment appeals. Bright and Careless note that decision in the case, Colonial School District v. Metroplex West Associates, L.P., undercuts a common argument by localities in relying on the automatic carryforward of residential appeals when defending against claims of uniformity clause violations.
June 03, 2020
Part II of a two-part series on the income tax rules applied to taxpayers recognizing cancellation of indebtedness income.
June 02, 2020
Tom Gallagher and Dennis Cohen discuss how the income tax rules relating to debt cancellation income work. This is Part One of two discussions on COD income.
April 30, 2020
Joe Bright advises real estate owners to consider filing an appeal of the assessed values assigned to properties for the tax year 2021.
April 21, 2020
Tom Gallagher and Dennis Cohen identify some of the income tax issues purchasers of distressed debt of non-publicly traded entities face when making individual investments, acquiring a portfolio of distressed debt at an unallocated price, and considering how to fund the acquisitions.
April 10, 2020
Thomas J. Gallagher and Dennis L. Cohen discuss the intricacies of section 467 lease agreements and the surprising and unexpected consequences.
April 07, 2020
Tom Gallagher and Dennis Cohen provide borrowers and lenders with some of the significant tax issues presented by attempts to restructure and renegotiate debtor/creditor relationships, whether by modifying the terms of the economic arrangement or restructuring the arrangement in its entirety.
March 28, 2020
Members of Cozen O'Connor's Coronavirus Task Force provide analysis of the CARES Act and how it will impact small businesses, distressed industries, employers and employees, taxes, and the health care, real estates, and energy industries.
February 24, 2020
Benjamin A. Bomrind, Anne M. Madonia, and Joshua C. Weinberger discuss this discontinuation of LIBOR and how clients should prepare.
November 07, 2024
In 2024, Best Lawyers received more than 100,000 client references and observed a 65% increase in client participation in their survey.
September 20, 2024
Christopher McLoon discussed preformation capital expenditure reimbursement in Tax Notes Federal, Volume 174.
September 18, 2024
Christopher McLoon discusses what PIP (partners interests in the partnership) allocations are and when and why they should be used.
September 04, 2024
Dan Schulder discusses the PA Commonwealth Court's ruling that Goodwill Industries is entitled to a real estate tax exemption and does not compete with commercial enterprises.
August 27, 2024
Christopher McLoon shares advice for businesses and their managers to avoid unintended tax consequences when forming a partnership.
August 15, 2024
Best Lawyers selected 242 Cozen O’Connor lawyers from 24 of the firm’s U.S. offices for inclusion in the 2025 edition of The Best Lawyers in America and Best Lawyers: Ones to Watch in America.
July 23, 2024
Chris McLoon discusses the Prevailing Wage and Apprenticeship (PWA) regulations' key points.
July 15, 2024
Dan Schulder and Heidi Schwartz discuss the Pennsylvania Commonwealth Court's ruling that the exemption for transfers of real estate from a trust to a beneficiary for no or nominal consideration also applies to transfers of interests in real estate companies.
June 14, 2024
Cheryl Upham was quoted in a Law360 article discussing concerns tax practitioners have raised regarding a proposed regulation from the Pennsylvania Department of Revenue.
June 11, 2024
Each candidate is evaluated on 12 indicators of peer recognition and professional achievement. Only 5 percent of attorneys are named Super Lawyers; only 2.5 percent of attorneys are listed as Rising Stars.
June 10, 2024
Chambers USA rankings are based on an “assessment of a firm’s work and opinions from external market sources, with an emphasis on client feedback.” In order to be ranked in the guide, lawyers and firms must demonstrate “sustained excellence.”
May 29, 2024
Chris McLoon discusses how taxpayers can qualify for increased renewable energy tax credits following the IRS' recent notice.
May 06, 2024
Richard Silpe and Nathan Rudy discuss the tax implications of the Department of Justice's proposal to reclassify marijuana from a Schedule I to a Schedule III controlled substance.
May 01, 2024
Chris McLoon discusses the U.S. Treasury's new rules for Real Estate Investment Trusts (REITs), which will affect how foreign investors are taxed.
April 18, 2024
Chris McLoon was quoted in a NYSSPCA article, originally published in Accounting Today, discussing tax-related issues in light of the upcoming election season.
March 29, 2024
Andrew Elbaz, Rory Godinho, Shane Hardy, Michael Osborne, Steven Weisz, and Kevin Zimka were named to the Canadian Legal Lexpert Directory for 2024.
January 31, 2024
The total consideration for the transactions is $182.5 million, subject to customary adjustments. The transactions are expected to close on February 5, 2024, subject to the satisfaction of certain closing conditions.
January 10, 2024
Cheryl Upham and Heidi Schwartz discuss changes to the tax treatment of grantor trusts which will finally conform Pennsylvania's rules to federal tax law.
December 18, 2023
Christopher McLoon discusses a Tax Court ruling that a limited partner's share of income may be subject to self-employment tax.
November 27, 2023
Chris McLoon and Wendy Venoit discuss the Internal Revenue Service’s proposed regulations concerning energy tax credits.
September 07, 2023
Cozen O’Connor is pleased to announce Wendy Enerson, Melissa Grossman, Susan Grueneberg, Suzanne Radcliff, Laura Reinhart, John Sullivan, and Cheryl Upham have been promoted to shareholder.
August 31, 2023
In this article, Mark outlines ten examples of challenges, ranging from limiting bank qualifications for debt service savings, and handling arbitrage earnings and swap termination payments, to addressing private use of bond-financed property and managing bond-financed property.
August 17, 2023
Best Lawyers selected 232 Cozen O’Connor lawyers from 24 of the firm’s U.S. offices for inclusion in the 2024 edition of The Best Lawyers in America.
May 31, 2023
New Jersey will automatically treat federal S corporations as New Jersey S corporations, effective for periods beginning on or after December 22, 2022.
May 15, 2023
McLoon has spent nearly three decades providing strategic tax guidance to major businesses, investors, and real estate developers.
March 14, 2023
Shane Hardy, Michael Osborne, Steven Weisz, and Kevin Zimka were named to the Canadian Legal Lexpert Directory for 2023.
November 30, 2022
U.S. News & World Report and Best Lawyers recognized Cozen O’Connor as a “Best Law Firm” in 30 practice areas nationwide and 115 practice areas regionally.
November 15, 2022
Cheryl Upham, vice chair of the firm’s Tax Group, was named a 2022 Bar Star for the Tax Section of the Philadelphia Bar Association.
October 17, 2022
Matthew Clyde co-authored the Bloomberg Tax Portfolio addressing the interplay of benefits and bankruptcy law.
September 20, 2022
The City of Philadelphia has extended the deadline for the filing of a first level review of real estate assessment appeals to October 14, 2022.
September 19, 2022
Cozen O’Connor announced veteran corporate tax attorney Kevin Zimka has joined its Vancouver office as a Shareholder.
August 30, 2022
Joseph Bright, Cheryl Upham, and Heidi Schwartz address how there is a lack of guidance when dealing with non-fungible tokens (NFTs) and what we expect from the states moving forward in Bloomberg Tax.
August 22, 2022
Geoffrey Ferrer, James Forsyth, J. Bruce Maffeo, Suzanne Mayes, Jason Shargel, and Anna Wermuth received the highest annual ratings from their peers.
July 26, 2022
Pennsylvania’s 2022-2023 budget, Act of Jul. 8, 2022, implements sweeping tax reform and revises some of Pennsylvania’s most business-unfriendly tax provisions.
June 02, 2022
Chambers USA, the leading annual guide to the top lawyers and law firms in the United States, has ranked 86 Cozen O’Connor lawyers as leaders in their respective fields in the guide’s 2022 edition.
June 01, 2022
Super Lawyers has selected 49 Cozen O'Connor attorneys to the 2022 Pennsylvania Super Lawyers and Rising Stars lists.
April 05, 2022
Joe Hill, Joe Bright, and Brianna Westbrooks discuss Councilmember Brooks' proposed tax on certain intangible property, including direct holdings in stocks and bonds, at 0.4 percent.
November 04, 2021
U.S. News & World Report and Best Lawyers recognized Cozen O’Connor as a “Best Law Firm” in 29 practice areas nationwide and 121 practice areas regionally.
September 27, 2021
Nathan Rudy and Rich Silpe discuss the draft tax legislation that was released as part of the “Build Back Better” budget reconciliation program and how it may impact the Section 1202 gain exclusion on the sale of qualified small business stock in a C corporation.
August 19, 2021
Best Lawyers selected 210 Cozen O’Connor lawyers from 23 of the firm’s nationwide offices for inclusion in the 2022 edition of The Best Lawyers in America.
May 26, 2021
Chambers USA, the leading annual guide to the top lawyers and law firms in the United States, has ranked 82 Cozen O’Connor lawyers as leaders in their respective fields in the guide’s 2021 edition; of those, 15 lawyers have been recognized nationally.
January 27, 2021
Joe Bright and Heidi Schwartz provide an analysis of Autozone Development Corp.’s appeal of a property tax assessment that is pending before the Pennsylvania Supreme Court.
December 04, 2020
Heidi Schwartz and Joe Bright co-authored an article in Bloomberg Tax addressing the reporting challenges and potential tax bills confronting employers whose employees are working from home in jurisdictions outside of the employer’s workplace during the COVID-19 pandemic.
November 05, 2020
U.S. News & World Report and Best Lawyers recognized Cozen O’Connor as a “Best Law Firm” in 25 practice areas nationwide and 115 practice areas regionally.
September 28, 2020
Tom Gallagher and Dennis Cohen are co-authors of an article published in the October 2020 issue of Pratt’s Journal of Bankruptcy Law.
September 17, 2020
Joe Bright and Heidi Schwartz co-authored an article published in Bloomberg Tax analyzing the Pennsylvania Commonwealth Court’s recent decision in Synthes USA HQ, Inc. v. Pennsylvania.
September 01, 2020
Thomas Gallagher and Dennis Cohen are co-authors of an article published in the Pratt’s Journal of Bankruptcy Law.
August 20, 2020
Best Lawyers selected 200 Cozen O’Connor lawyers from 23 of the firm’s nationwide offices for inclusion in the 2021 edition of The Best Lawyers in America© (Copyright 2020 by Woodward/White, Inc., of Aiken, SC).
August 11, 2020
Joseph Bright and Bob Careless co-authored an article, published by Bloomberg Tax, analyzing a recent decision by the Commonwealth Court of Pennsylvania that is favorable to commercial taxpayers facing selective reverse assessment appeals. Bright and Careless note that decision in the case, Colonial School District v. Metroplex West Associates, L.P., undercuts a common argument by localities in relying on the automatic carryforward of residential appeals when defending against claims of uniformity clause violations.
June 10, 2020
Transaction Results in Utz Going Public After Nearly 100 Years as Family Business.
June 03, 2020
Part II of a two-part series on the income tax rules applied to taxpayers recognizing cancellation of indebtedness income.
June 02, 2020
Tom Gallagher and Dennis Cohen discuss how the income tax rules relating to debt cancellation income work. This is Part One of two discussions on COD income.
May 14, 2020
Chambers USA, the leading annual guide to the top lawyers and law firms in the United States, has ranked 63 Cozen O’Connor lawyers as leaders in their respective fields in the guide’s 2020 edition.
April 30, 2020
Joe Bright advises real estate owners to consider filing an appeal of the assessed values assigned to properties for the tax year 2021.
April 21, 2020
Tom Gallagher and Dennis Cohen identify some of the income tax issues purchasers of distressed debt of non-publicly traded entities face when making individual investments, acquiring a portfolio of distressed debt at an unallocated price, and considering how to fund the acquisitions.
April 10, 2020
Thomas J. Gallagher and Dennis L. Cohen discuss the intricacies of section 467 lease agreements and the surprising and unexpected consequences.
April 07, 2020
Tom Gallagher and Dennis Cohen provide borrowers and lenders with some of the significant tax issues presented by attempts to restructure and renegotiate debtor/creditor relationships, whether by modifying the terms of the economic arrangement or restructuring the arrangement in its entirety.
March 28, 2020
Members of Cozen O'Connor's Coronavirus Task Force provide analysis of the CARES Act and how it will impact small businesses, distressed industries, employers and employees, taxes, and the health care, real estates, and energy industries.
February 24, 2020
Benjamin A. Bomrind, Anne M. Madonia, and Joshua C. Weinberger discuss this discontinuation of LIBOR and how clients should prepare.