Charles W. Cope | Representative Matters
This links to the home page
Charles  W. Cope


General Business Taxation
Intellectual Property Tax Planning
U.S. Inbound Taxation
Transfer Pricing Planning and Controversy
U.S. Outbound Taxation
U.S. Income Tax Treaties


LL.M, taxation, New York University Law School

JD, University of Chicago Law School

MA, economics, University of Chicago

BA, economics, cum laude, Rice University


New York, 1983

United States Tax Court, 1984

District of Columbia, 1992
Charles W. Cope
Tel: 212-596-7094 | 917-846-4223
Fax: 646-350-1445
v-card icon V-Card
  • Private Equity - Acquisition Planning

    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.

  • Fortune 500 Company - Business Restructuring 

    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.

  • Domestic-Foreign Joint Venture

    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.

  • U.S. Tech Company - Migration of Intellectual Property

    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.

  • Fortune 500 Company - Migration of 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.

  • European Shipping Company - Cross-Border Leasing

    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.

  • European Service Company - Inbound Financing

    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.

  • European Retailer - U.S. eCommerce

    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.

  • Asian Mulinational - U.S. Business Restructuring

    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