Mr. Cope advised a private equity fund in connection with its acquisition of a U.S. target.  The acquisition involved opinions on U.S. income tax treaty benefits, debt-equity issues and whether reporting was required under the U.S. controlled foreign corporation rules.

Mr. Cope led a team that developed and implemented Swiss and Hong Kong principal companies for a Fortune 500 consumer products company.  Concurrently, the client restructured its distribution subsidiaries to limited-risk distributors or commissionaires.

Working with attorneys representing a U.S. investment bank, Mr. Cope developed and implemented a foreign joint venture between his client, a closely held non-US retail group and the U.S. bank  to own and exploit  intellectual property rights.

Mr. Cope developed and implemented an internal partnership between a U.S. parent and one of its foreign subsidiaries to develop and exploit the group’s intellectual property.

Mr. Cope developed and implemented a transfer of a portfolio of trademarks and copyrights by a Fortune 500 company to one of its European subsidiaries. The transaction was structured to take advantage of section 367(d) and the U.S. tax attributes of the group.

Working with attorneys and other advisors in several jurisdictions, Mr. Cope co-developed an ownership structure for a foreign company operating vessels in U.S. territorial waters.

Mr. Cope developed and implemented a cross-border financing transaction involving the U.S. subsidiary of a European parent company and a related foreign subsidiary.

Mr. Cope developed a U.S. limited-risk distributor structure for a foreign online retailer that permitted the  retailer to sell online in the U.S. market without creating risk of a U.S. trade or business.

Mr. Cope advised a major Asian multinational on the multi-step reorganization of its U.S. corporate group in a manner that was tax-free in the United States