Tax

Featured Publication:

An Energy/Production Credit Boost – IRS Issues Notice with Safe Harbor for Domestic Content [Alert]

Chris McLoon discusses how taxpayers can qualify for increased renewable energy tax credits following the IRS' recent notice.

More

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

  • 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
  • Counsel clients on structured finance, project finance, leasing transactions, and the use of derivatives to hedge business operations and debt issuances
  • 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
  • Provide tax planning prior to incorporation or securities offerings
  • Guide the organization and syndication of private equity funds
  • Structure cross-border transactions with the goal of minimizing U.S. and Canadian federal income tax consequences
  • Advise clients on corporate tax issues related to the use of exchangeable shares and the distribution of assets to shareholders
  • Provide guidance on Canadian flow-through limited partnership offerings

Real Estate

  • Advise clients on the optimal structure for real estate investments
  • 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
  • Counsel clients regarding securitizations, including real estate mortgage investment conduits (REMICs) and other asset securitizations
  • Advise clients with real estate investments that qualify for safe harbor protection
  • Assist with tax-free exchanges of like-minded properties

Tax-Exempt Organizations

  • Serve public charities, museums, trade associations, health care providers, veterans’ organizations, and private foundations
  • Advise on the formation of non-profit corporations and charitable trusts
  • Obtain tax rulings and federal, state, and local tax exemptions
  • Counsel high net worth individuals and businesses on the advantages of establishing and operating private foundations

U.S. State and Local Tax

  • Represent clients in state and local tax controversies and litigation 
  • Advocate for legislative and regulatory changes in state and local tax codes
  • Advise clients about variations in state tax laws and perform multi-state tax analyses

Tax Compliance, Controversy, and Litigation

  • Render formal tax opinions in connection with specific transactions and obtain rulings from the Internal Revenue Service and state and local tax authorities
  • 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.

 

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Experience

Publications

Allocating Preformation Capital Expenditure Reimbursement

September 20, 2024

Christopher McLoon discussed preformation capital expenditure reimbursement in Tax Notes Federal, Volume 174.

Drafting Partnership Agreements: Ensuring You Get the Returns You Bargained For [Alert]

September 18, 2024

Christopher McLoon discusses what PIP (partners interests in the partnership) allocations are and when and why they should be used.

PA Commonwealth Court Decides Tax Exemption for Goodwill Industries [Alert]

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.

Forming a Partnership/LLC: A Checklist for Avoiding Pitfalls [Alert]

August 27, 2024

Christopher McLoon shares advice for businesses and their managers to avoid unintended tax consequences when forming a partnership.

A Cocktail of Labor Policy, Energy Policy & Tax Policy: Prevailing Wage and Apprenticeship Rules [Alert]

July 23, 2024

Chris McLoon discusses the Prevailing Wage and Apprenticeship (PWA) regulations' key points.

Realty Transfer Tax Regulation Invalidated by Commonwealth Court [Alert]

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.

An Energy/Production Credit Boost – IRS Issues Notice with Safe Harbor for Domestic Content [Alert]

May 29, 2024

Chris McLoon discusses how taxpayers can qualify for increased renewable energy tax credits following the IRS' recent notice.

Tax Benefits to Arise from Department of Justice’s Move to Reclassify Marijuana [Alert]

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.

Treasury Issues Game-Changing Final Regulations on Domestically Controlled REIT Status [Alert]

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.

Pennsylvania Amends Tax Treatment of Grantor Trusts as of January 1, 2025 [Alert]

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.

Tax Court: Limited Partner Exception to Self-Employment Taxes Is...Limited [Alert]

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.

IRS Proposes Helpful Rules for Energy Tax Credits [Alert]

November 27, 2023

Chris McLoon and Wendy Venoit discuss the Internal Revenue Service’s proposed regulations concerning energy tax credits.

Top (Bottom?) Ten of Tax Headaches (Challenges) for Municipal Bond Issuers

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.

New Jersey Eliminates S Election as of December 22, 2022 [Alert]

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.

Employee Benefits in Bankruptcy - Portfolio 380 [Bloomberg Tax]

October 17, 2022

Matthew Clyde co-authored the Bloomberg Tax Portfolio addressing the interplay of benefits and bankruptcy law.

City of Philadelphia Real Estate Assessment Appeals [Alert]

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.

Pennsylvania Enacts Record Tax Reform [Alert]

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.

Philadelphia City Councilmember Introduces Bill To Impose Wealth Tax on Stocks and Bonds [Alert]

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.

House Ways and Means Committee Proposes Reduction of QSBS Exclusion [Alert]

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.

2021 Could Increase Uniformity of Taxation of Real Estate in Pennsylvania

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.

As the Pandemic Spreads, So Does the Reach of State Nexus

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.

An Overview of the Rules Regarding the Realization and Recognition of Debt Cancellation Income- Part II

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.

Pennsylvania Commonwealth Court Sustains Revenue’s Source Analysis

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.

An Overview of the Rules Regarding the Realization and Recognition of Debt Cancellation Income- Part I

September 01, 2020

Thomas Gallagher and Dennis Cohen are co-authors of an article published in the Pratt’s Journal of Bankruptcy Law.

Automatic Carryforward of Prior Residential Appeals Is Not Evidence of Uniform Assessments in Pennsylvania

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.

Debt Cancellation Income Arising in Connection with the Ownership of Real Estate

June 03, 2020

Part II of a two-part series on the income tax rules applied to taxpayers recognizing cancellation of indebtedness income.

An Overview of the Rules Regarding the Realization and Recognition of Debt Cancellation 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.

Real Estate Tax Appeals [Alert]

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.

Tax Issues to Consider in Buying or Holding Distressed Debt

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.

Federal Income Tax Consequences of Defaults and Restructurings Under Lease Agreements

April 10, 2020

Thomas J. Gallagher and Dennis L. Cohen discuss the intricacies of section 467 lease agreements and the surprising and unexpected consequences.

Overview of the Federal Income Tax Consequences of Defaults and Restructurings Under Loan Agreements

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.

Summary and Analysis of Key Provisions of the CARES Act

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.

Transitioning for the End of LIBOR [Alert]

February 24, 2020

Benjamin A. Bomrind, Anne M. Madonia, and Joshua C. Weinberger discuss this discontinuation of LIBOR and how clients should prepare.

In The News

Cozen O’Connor Recognized as a “Best Law Firm” in 31 Practice Areas Nationwide, 54 Practice Areas Regionally

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.

Allocating Preformation Capital Expenditure Reimbursement

September 20, 2024

Christopher McLoon discussed preformation capital expenditure reimbursement in Tax Notes Federal, Volume 174.

Drafting Partnership Agreements: Ensuring You Get the Returns You Bargained For [Alert]

September 18, 2024

Christopher McLoon discusses what PIP (partners interests in the partnership) allocations are and when and why they should be used.

PA Commonwealth Court Decides Tax Exemption for Goodwill Industries [Alert]

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.

Forming a Partnership/LLC: A Checklist for Avoiding Pitfalls [Alert]

August 27, 2024

Christopher McLoon shares advice for businesses and their managers to avoid unintended tax consequences when forming a partnership.

Best Lawyers Honors More Than 200 Cozen O'Connor Attorneys in its Best Lawyers in America 2025 Edition

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.

A Cocktail of Labor Policy, Energy Policy & Tax Policy: Prevailing Wage and Apprenticeship Rules [Alert]

July 23, 2024

Chris McLoon discusses the Prevailing Wage and Apprenticeship (PWA) regulations' key points.

Realty Transfer Tax Regulation Invalidated by Commonwealth Court [Alert]

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.

Pa. Business Income Rule Sparks Worries of Tax Overreach

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.

31 Cozen O'Connor Attorneys Named Pennsylvania Super Lawyers and Rising Stars

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.

Nearly 100 Cozen O’Connor Lawyers, 27 Practices Earn Top Recognition in Chambers USA 2024 Guide

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.”

An Energy/Production Credit Boost – IRS Issues Notice with Safe Harbor for Domestic Content [Alert]

May 29, 2024

Chris McLoon discusses how taxpayers can qualify for increased renewable energy tax credits following the IRS' recent notice.

Tax Benefits to Arise from Department of Justice’s Move to Reclassify Marijuana [Alert]

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.

Treasury Issues Game-Changing Final Regulations on Domestically Controlled REIT Status [Alert]

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.

After Tax Day, Several Tax and Budget Policy Issues Gain Prominence

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.

Six Cozen O'Connor Attorneys Named to the 2024 Canadian Legal Lexpert Directory

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.

Cozen O’Connor Advises Utz Brands, Inc. on Definitive Agreement to Sell Three Manufacturing Facilities and Good Health® and R.W. Garcia® Brands

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.

Pennsylvania Amends Tax Treatment of Grantor Trusts as of January 1, 2025 [Alert]

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.

Tax Court: Limited Partner Exception to Self-Employment Taxes Is...Limited [Alert]

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.

IRS Proposes Helpful Rules for Energy Tax Credits [Alert]

November 27, 2023

Chris McLoon and Wendy Venoit discuss the Internal Revenue Service’s proposed regulations concerning energy tax credits.

Cozen O’Connor Announces Seven New Shareholders

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.

Top (Bottom?) Ten of Tax Headaches (Challenges) for Municipal Bond Issuers

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.

Best Lawyers Honors More Than 200 Cozen O'Connor Attorneys to its Best Lawyers in America 2024 Edition

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.

New Jersey Eliminates S Election as of December 22, 2022 [Alert]

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.

Veteran Tax Attorney Christopher S. McLoon Joins Cozen O’Connor in Philadelphia

May 15, 2023

McLoon has spent nearly three decades providing strategic tax guidance to major businesses, investors, and real estate developers.

Four Cozen O'Connor Attorneys Named to the 2023 Canadian Legal Lexpert Directory

March 14, 2023

Shane Hardy, Michael Osborne, Steven Weisz, and Kevin Zimka were named to the Canadian Legal Lexpert Directory for 2023.

Cozen O’Connor Recognized as a “Best Law Firm” in 30 Practice Areas Nationwide, 115 Practice Areas Regionally

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.

Philadelphia Bar Association Names Cheryl Upham 2022 Bar Star

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.

Employee Benefits in Bankruptcy - Portfolio 380 [Bloomberg Tax]

October 17, 2022

Matthew Clyde co-authored the Bloomberg Tax Portfolio addressing the interplay of benefits and bankruptcy law.

City of Philadelphia Real Estate Assessment Appeals [Alert]

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.

Cozen O’Connor Adds Veteran Tax Attorney Kevin Zimka to Canadian Tax Group

September 19, 2022

Cozen O’Connor announced veteran corporate tax attorney Kevin Zimka has joined its Vancouver office as a Shareholder.

The Devil Is in the Details When Handling NFTs and State Taxes

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.

Six Cozen O’Connor Lawyers Named 2023 “Lawyers of the Year” by Best Lawyers

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.

Pennsylvania Enacts Record Tax Reform [Alert]

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.

Chambers Ranks 86 Cozen O’Connor Lawyers, 22 Practice Areas in Chambers USA 2022 Guide

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.

49 Cozen O'Connor Attorneys Named Pennsylvania Super Lawyers and Rising Stars

June 01, 2022

Super Lawyers has selected 49 Cozen O'Connor attorneys to the 2022 Pennsylvania Super Lawyers and Rising Stars lists.

Philadelphia City Councilmember Introduces Bill To Impose Wealth Tax on Stocks and Bonds [Alert]

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.

Cozen O’Connor Recognized as a “Best Law Firm” in 29 Practice Areas Nationwide, 121 Practice Areas Regionally

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.

House Ways and Means Committee Proposes Reduction of QSBS Exclusion [Alert]

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.

More Than 205 Cozen O’Connor Attorneys Named Best Lawyers and Ones to Watch By The Best Lawyers In America

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.

82 Cozen O’Connor Lawyers, 19 Practices Earn Top Recognition in Chambers USA 2021 Guide

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.

2021 Could Increase Uniformity of Taxation of Real Estate in Pennsylvania

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.

As the Pandemic Spreads, So Does the Reach of State Nexus

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.

Cozen O’Connor Recognized as a “Best Law Firm” in 25 Practice Areas Nationwide, 115 Practice Areas Regionally

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.

An Overview of the Rules Regarding the Realization and Recognition of Debt Cancellation Income- Part II

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.

Pennsylvania Commonwealth Court Sustains Revenue’s Source Analysis

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.

An Overview of the Rules Regarding the Realization and Recognition of Debt Cancellation Income- Part I

September 01, 2020

Thomas Gallagher and Dennis Cohen are co-authors of an article published in the Pratt’s Journal of Bankruptcy Law.

200 Cozen O’Connor Attorneys Named Best Lawyers and Ones to Watch By The Best Lawyers In America

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).

Automatic Carryforward of Prior Residential Appeals Is Not Evidence of Uniform Assessments in Pennsylvania

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.

Cozen O’Connor Guides Utz Quality Foods in Business Combination Agreement with Collier Creek Holdings to Form Utz Brands, Inc.

June 10, 2020

Transaction Results in Utz Going Public After Nearly 100 Years as Family Business.

Debt Cancellation Income Arising in Connection with the Ownership of Real Estate

June 03, 2020

Part II of a two-part series on the income tax rules applied to taxpayers recognizing cancellation of indebtedness income.

An Overview of the Rules Regarding the Realization and Recognition of Debt Cancellation 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.

63 Cozen O’Connor Lawyers, 16 Practices Earn Top Recognition in Chambers USA 2020 Guide

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.

Real Estate Tax Appeals [Alert]

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.

Tax Issues to Consider in Buying or Holding Distressed Debt

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.

Federal Income Tax Consequences of Defaults and Restructurings Under Lease Agreements

April 10, 2020

Thomas J. Gallagher and Dennis L. Cohen discuss the intricacies of section 467 lease agreements and the surprising and unexpected consequences.

Overview of the Federal Income Tax Consequences of Defaults and Restructurings Under Loan Agreements

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.

Summary and Analysis of Key Provisions of the CARES Act

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.

Transitioning for the End of LIBOR [Alert]

February 24, 2020

Benjamin A. Bomrind, Anne M. Madonia, and Joshua C. Weinberger discuss this discontinuation of LIBOR and how clients should prepare.

Contacts

Richard J. Silpe

Chair, Tax

rsilpe@cozen.com

(215) 665-2704

Cheryl A. Upham

Vice Chair, Tax

cupham@cozen.com

(215) 665-4193

People

Awards

Cozen O’Connor Recognized as a “Best Law Firm” in 31 Practice Areas Nationwide, 54 Practice Areas Regionally

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.

31 Cozen O'Connor Attorneys Named Pennsylvania Super Lawyers and Rising Stars

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.

Nearly 100 Cozen O’Connor Lawyers, 27 Practices Earn Top Recognition in Chambers USA 2024 Guide

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.”

Best Lawyers Honors More Than 200 Cozen O'Connor Attorneys to its Best Lawyers in America 2024 Edition

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.

Four Cozen O'Connor Attorneys Named to the 2023 Canadian Legal Lexpert Directory

March 14, 2023

Shane Hardy, Michael Osborne, Steven Weisz, and Kevin Zimka were named to the Canadian Legal Lexpert Directory for 2023.

Cozen O’Connor Recognized as a “Best Law Firm” in 30 Practice Areas Nationwide, 115 Practice Areas Regionally

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.

Philadelphia Bar Association Names Cheryl Upham 2022 Bar Star

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.

Chambers Ranks 86 Cozen O’Connor Lawyers, 22 Practice Areas in Chambers USA 2022 Guide

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.

49 Cozen O'Connor Attorneys Named Pennsylvania Super Lawyers and Rising Stars

June 01, 2022

Super Lawyers has selected 49 Cozen O'Connor attorneys to the 2022 Pennsylvania Super Lawyers and Rising Stars lists.

Cozen O’Connor Recognized as a “Best Law Firm” in 29 Practice Areas Nationwide, 121 Practice Areas Regionally

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.

More Than 205 Cozen O’Connor Attorneys Named Best Lawyers and Ones to Watch By The Best Lawyers In America

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.

82 Cozen O’Connor Lawyers, 19 Practices Earn Top Recognition in Chambers USA 2021 Guide

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.

Cozen O’Connor Recognized as a “Best Law Firm” in 25 Practice Areas Nationwide, 115 Practice Areas Regionally

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.

200 Cozen O’Connor Attorneys Named Best Lawyers and Ones to Watch By The Best Lawyers In America

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).

63 Cozen O’Connor Lawyers, 16 Practices Earn Top Recognition in Chambers USA 2020 Guide

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.

Cozen O’Connor Recognized As a Best Law Firm in 24 Practice Areas Nationwide, 106 Practice Areas Regionally

November 05, 2019

The U.S. News – Best Lawyers “Best Law Firms” rankings are based on a rigorous evaluation process that includes the collection of client and lawyer evaluations and peer review from leading attorneys in their field.

Six Cozen O’Connor Lawyers Named 2020 “Lawyers of the Year” By Best Lawyers in America

August 28, 2019

Cozen O’Connor is proud to announce that six of the firm’s lawyers have been recognized as “Lawyers of the Year” in their respective practices by Best Lawyers in America.

138 Cozen O’Connor Attorneys Named to the Best Lawyers in America

August 28, 2019

Best Lawyers selected 138 Cozen O’Connor lawyers from 21 of the firm’s national offices for inclusion in the 2020 edition of The Best Lawyers in America.

57 Cozen O’Connor Lawyers, 16 Practices Earn Top Recognition in Chambers USA 2019 Guide

April 25, 2019

Chambers USA, the leading annual guide to the top lawyers and law firms in the USA, has ranked 57 Cozen O’Connor lawyers as leaders in their respective fields in the Guide’s 2019 edition.

125 Cozen O’Connor Attorneys Named to the Best Lawyers in America

August 22, 2018

One hundred twenty-five Cozen O’Connor lawyers from 20 of the firm’s national offices have been selected for inclusion in the 2018 edition of The Best Lawyers in America.

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