SERVICE OFFERINGSGeneral Business Taxation
Intellectual Property Tax Planning
U.S. Inbound Taxation
Transfer Pricing Planning and Controversy
U.S. Outbound Taxation
U.S. Income Tax Treaties
EDUCATIONLL.M, taxation, New York University Law School
JD, University of Chicago Law School
MA, economics, University of Chicago
BA, economics, cum laude, Rice University
ADMISSIONSNew York, 1983
United States Tax Court, 1984
District of Columbia, 1992
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