Mr. Cope has advised domestic and foreign clients in an array of industries engaged in a wide range of business transactions.  Below are summaries of some illustrative transactions he has completed.  Please click on each item for additional detail.

• 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.

• European Parmaceutical Company-U.S. Settlement Payments

  Mr. Cope issued various tax opinions to a foreign pharmaceutical company concerning various U.S. tax issues arising in connection with the settlement of claims agianst a major U.S. pharmacuetical company.

• U.S. Biotech Company - Milestone Payments

  Mr. Cope issues a tax opinion concerning the taxation of milestone payments made by a U.S. biotech company to a foreign developer.

• U.S. Income Tax Treaties - Qualification for Benefits

  Mr. Cope issued an opinion to a foreign multinational that a subsidiary qualified for the benefits of the relevant U.S. income tax treaty under the active trade or business provision of the article on limitation on benefits.

• U.S. Tech Company - Expansion Overseas

  Mr. Cope advised a public U.S. technology company in connection with its expansion into the European and Asia markets.

• U.S. Tech Company -- Foreign Tax Credit Planning

  Mr.Cope advised a major U.S. technology company in connection with a transaction to generate significant amounts of foreign source income in order to allow it to claim foreign tax credits.

• Asian Automaker-Finance Company

  Mr. Cope advised a foreign automaker in connection with the transition of certain finance-related business activities from its U.S. finance subsidiary to a non-U.S. subsidiary. 

• Asian Tech Company-Acquisition of Patent Portfolio 

  Mr. Cope advised a major Asian technology company in connection with its bid to by a porfolio of patents from a domestic seller.

• 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

• 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.

• 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.

• 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 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.

• 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.

• 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.

• 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.

• Asian Airline - U.S. Operations

  Mr. Cope advised a foreign airline in connection with various issues arising from its U.S. operations.

• AsianTech Company - U.S. Operations

  Mr. Cope advised a foreign technolgy company in connection with its overall business structure and the U.S. tax implications of that structure.

• European Shipping Company - U.S. Joint Venture

  Mr. Cope advised a foreign shipping company in connection with its participation in a joint venture to modify and lease vessels to the U.S. military.