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Perpsective clients should contact Mr. Cope by email or phone to arrange an intial consultation at no charge. Perspective clients should not send Mr. Cope any business documents (e.g., contracts, descriptions of proposed transactions, financial information, economic studies, etc.) prior to signing an engagement letter with the firm.
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Yes. Mr. Cope regularly represents non-U.S. corporations and non-residents in connection with their U.S. business or investment activities.
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Yes. Mr. Cope has experience reviewing tax opinions prepared by other advisors for errors and omissions either in conection with financial audits or in conection with a significant transaction in which his client was seeking assurance that the work of another tax advisor was correct.
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Mr. Cope can prepare tax opinions suitable for FIN 48 purposes, and he has substantial experience working with CPAs on tax issues arising in financial audits.
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Mr. Cope can represent a client before the IRS. He also can represent a client in the courts should the issue remain unresolved after Appeals. He also can initiate a MAP under an income tax treaty in the case of a cross-border tax dispute should the need arise.
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Mr. Cope can represent a client seeking a private letter ruling from the IRS. The IRS will not rule on many tax questions; however, and in certain cases the likelihood of obtaining a ruling is remote.
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Mr. Cope can represent a client seeking an APA; either a bilateral APA or a unilateral APA.
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Mr. Cope can provide advice to client on questions of state and local tax law. However, Mr. Cope generally cannot provide advice on questions of Connecticut law, including Connecticut tax law.
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Mr. Cope is not admitted to practice law in any foreign jurisdiction, and he does not give any advice on foreign law or represent clients in foreign courts. He has worked with many foreign advisors over the years, and he can refer clients to an appropriate foreign advisor to advise them on their issues.
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In general, it is not cost effective for a client to hire Mr.Cope to prepare such documentation, but he can hire an economist for a client under a Kovel agreement and review such documentation.
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Mr. Cope does not prepare and file tax returns for clients, but he can refer clients to a suitable accountant to do this work. He can review tax returns prepared by an accountant to confirm positions taken on the return. He also can advise on penalties and disclosure issues associated with the filing of tax returns.
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Mr. Cope is not a CPA. He does not provide accounting services or financial oversight services of any type.