Mr. Cope has written and lectured extensively on U.S. cross-border tax issues during the more than 25 years he has practiced in Washington and New York.  The articles he has published and the lectures he has delivered are listed below.

• Taxation of Indirect Share Transfers: Recent Developments in India and Related Policy Considerations, 44 Tax Management International Journal

  January 2015

  With Parul Jain, BMR & Associates LLP

• On the Vodafone Roller Coaster: India’s Supreme Court Provides Multinationals a Short-Lived Solace, 41 Tax Management International Journal

  April 2012

  With Vikas Vasal

• Self-Initiated Transfer Pricing Adjustments, or Virtue Unrewarded, Tax Notes Today

  November 18, 2010

  With Sean F. Foley

• The Ninth Circuit Affirms the Tax Court's Decision in Xilinx, But Some Issues Remain Unresolved, 39 Tax Management International Journal

  June 2010

  With Thoms M. Zollo

• Increasing Ties with the Southern Cone: A Review of the Recently Signed Income Tax Treaty Between Chile and the United States, 39 Tax Management International Journa

  June 2010

  With José Leiman

• Veritas Vincit, 126 Tax Notes 839

  February 15, 2010

  With Stephen Blough and Thomas M. Zollo

• Xilinx: A Case Study in Judicial Activism, 38 Tax Management International Journal

  August 2009

  With Thomas M. Zollo

• Determining Taxable Income in Connection with a Cost Sharing Arrangement: A Review and Analysis of the Temporary Cost Sharing Regulations, 87 Taxes--The Tax Magazine 5

  May 2009

  With Stephen Blough and Thomas Zollo

• Intangible Property and Tax Planning for Multinational Enterprises, Managing Tax and Intellectual Property, Tax Planning International Special Report

  April 2009

  with Thomas M. Zollo

• The Application of §304 to a Disposition of Shares in a U.S. Real Property Holding Corporation, 38 Tax Management International Journal
   

  March 2009

  With Jeffrery Farrell

• Branch Taxation OECD Style: A Review of New Draft Article 7 (Business Profits) of the OECD Model Tax Convention, 37 Tax Management International Journal

  November 2008

• OECD’s Draft Transfer Pricing Report Addresses Business Restructuring Issues, Daily Tax Report

  October 30, 2008

  with Stephen Blough

• Transfer Pricing for Services: The Temporary Regulations, 84 Taxes--The Tax Magazine 35

  October 2006

  with Stephen Blough and Thomas Zollo

• Limitations on Transfer Price Adjustment under the Commensurate with Income Standard, 104 Journal of Taxation 112

  February 2006

• Methods to Determine Taxable Income in Connection with a Cost Sharing Arrangement: 
  A Review and Analysis of the Proposed Cost Sharing Regulations, 83 Taxes--The Tax Magazine 19

  January 2005

  with Clark Chandler and Thomas Zollo

• An Analysis of the New Japan-United States Income Tax Treaty, 32 Tax Notes Int'l 1119

  June 2003

  David F. Chan

• Using Hybrid Restructuring Transactions to Address Structural Foreign Tax Credit Problems, New York University 56th Institute of Federal Taxation

  October 1997

• Will European Monetary Convergence be a Taxable Event?  Some Thoughts on the Conversion to the Euro, 26 Tax Management International Journal 526

  October 1997

  with Carol A. Dunahoo

• Selected Highlights of the New US-Canada Protocol and the New US-France Treaty, 50 Bulletin for International Fiscal Documentation 187

  May 1996

  with Mary C. Bennet

• Final DASTM Regulations Provide Significant Advantages to Businesses Operating in Hyperinflationary Countries, 9 Tax Notes International 753

  September 1994

  with Robert A. Katcher

• U.S. Income Tax Treaties:  Notes and Comments on Some Present and Future Policies, TAXES

  December 1993

• Limitations on Treaty Shopping with Respect to Dividends and Non-Portfolio Interest, Foreign Investment in the United States, Practicing Law Institute

  June 1989

  with Leslie J. Schreyer

• Cross-Border Financings, Institute on Federal Taxation, New York University

  May 1989

  with Leslie J. Schreyer

• The Foreign Tax Credit and Source of Income Rules Revisited, 18th Annual Institute on International Taxation, Practicing Law Institute

  June 1987

  with Leslie J. Schreyer

• Taxation of the Dual-Resident Alien: The Interaction of Section 7701(b) and United States Income Tax Treaties, 45 International Business Law Journal No. 1.

  January 1986

  with Leslie J. Schreyer

• FIRPTA: Some Planning Techniques, Practicing Law Institute

   

  June 1985

  with Leslie J. Schreyer