Thomas J. Gallagher

Member

Philadelphia

(215) 665-4656

(215) 665-2013

Thomas's practice focuses on the tax aspects of commercial transactions of all types, including mergers and acquisitions, private and institutional joint venture transactions, real estate and venture capital transactions, projects involving utilization of the rehabilitation tax credit, and pension fund investments in real estate and real estate partnerships.

Thomas often handles the structuring and review of a variety of collective investment vehicles, including public and private real estate partnerships and public and private REITs. He has also represented institutional clients, including REITs and TEFRA partnerships, in connection with ruling requests and controversies with the Internal Revenue Service.

Thomas earned his undergraduate degree, magna cum laude, in economics from the University of Pennsylvania, where he was a member of Phi Beta Kappa. He earned his law degree, cum laude, from the University of Pennsylvania Law School, where he was a member of the Order of the Coif.

Experience

News

More Than 205 Cozen O’Connor Attorneys Named Best Lawyers and Ones to Watch By The Best Lawyers In America

August 19, 2021

Best Lawyers selected 210 Cozen O’Connor lawyers from 23 of the firm’s nationwide offices for inclusion in the 2022 edition of The Best Lawyers in America.

82 Cozen O’Connor Lawyers, 19 Practices Earn Top Recognition in Chambers USA 2021 Guide

May 26, 2021

Chambers USA, the leading annual guide to the top lawyers and law firms in the United States, has ranked 82 Cozen O’Connor lawyers as leaders in their respective fields in the guide’s 2021 edition; of those, 15 lawyers have been recognized nationally.

More Than 200 Cozen O’Connor Attorneys Named Best Lawyers and Ones to Watch By The Best Lawyers In America

August 20, 2020

Best Lawyers selected 201 Cozen O’Connor lawyers from 23 of the firm’s nationwide offices for inclusion in the 2021 edition of The Best Lawyers in America© (Copyright 2020 by Woodward/White, Inc., of Aiken, SC).

63 Cozen O’Connor Lawyers, 16 Practices Earn Top Recognition in Chambers USA 2020 Guide

May 14, 2020

Chambers USA, the leading annual guide to the top lawyers and law firms in the United States, has ranked 63 Cozen O’Connor lawyers as leaders in their respective fields in the guide’s 2020 edition.

138 Cozen O’Connor Attorneys Named to the Best Lawyers in America

August 28, 2019

Best Lawyers selected 138 Cozen O’Connor lawyers from 21 of the firm’s national offices for inclusion in the 2020 edition of The Best Lawyers in America.

Seven Cozen O’Connor Lawyers Named 2019 “Lawyers of the Year” by Best Lawyers in America

August 31, 2018

Cozen O’Connor is proud to announce that seven of the firm’s lawyers have been recognized as “Lawyers of the Year” in their respective practices by Best Lawyers in America, one of the oldest and most highly regarded peer review publications in the legal profession.

126 Cozen O’Connor Attorneys Named to the Best Lawyers in America

August 22, 2018

One hundred twenty-six Cozen O’Connor lawyers from 20 of the firm’s national offices have been selected for inclusion in the 2018 edition of The Best Lawyers in America.

Fifty-four Cozen O’Connor Attorneys Named 2018 Pennsylvania Super Lawyers and Rising Stars

June 12, 2018

Super Lawyers has named 54 Cozen O'Connor attorneys to its 2018 Pennsylvania Super Lawyers and Rising Stars lists.

Can real estate brokers cash in on this tax deduction?

March 13, 2018

Thomas Gallagher, a member of Cozen O'Connor's Tax group, spoke with New York Real Estate News about the impact the tax deduction may have on real estate brokers.

100 Cozen O’Connor Lawyers Named to the Best Lawyers in America

August 23, 2017

Lawyers were selected for inclusion in the 2018 edition based on a rigorous peer-review that has been developed and defined for more than 30 years.

Publications

An Overview of the Rules Regarding the Realization and Recognition of Debt Cancellation Income- Part II

September 28, 2020

Tom Gallagher and Dennis Cohen are co-authors of an article published in the October 2020 issue of Pratt’s Journal of Bankruptcy Law.

An Overview of the Rules Regarding the Realization and Recognition of Debt Cancellation Income- Part I

September 01, 2020

Thomas Gallagher and Dennis Cohen are co-authors of an article published in the Pratt’s Journal of Bankruptcy Law.

Proposed Regulations Provide Guidance for the Carried Interest Rules — Six Important Takeaways [Alert]

August 05, 2020

Tom Gallagher discusses the IRS's Proposed Rulemaking setting forth guidance for the carried interest rules under Code Sec. 1061 that were enacted as part of the Tax Cuts and Jobs Act.

Debt Cancellation Income Arising in Connection with the Ownership of Real Estate

June 03, 2020

Part II of a two-part series on the income tax rules applied to taxpayers recognizing cancellation of indebtedness income.

An Overview of the Rules Regarding the Realization and Recognition of Debt Cancellation Income

June 02, 2020

Tom Gallagher and Dennis Cohen discuss how the income tax rules relating to debt cancellation income work. This is Part One of two discussions on COD income.

Tax Issues to Consider in Buying or Holding Distressed Debt

April 21, 2020

Tom Gallagher and Dennis Cohen identify some of the income tax issues purchasers of distressed debt of non-publicly traded entities face when making individual investments, acquiring a portfolio of distressed debt at an unallocated price, and considering how to fund the acquisitions.

Federal Income Tax Consequences of Defaults and Restructurings Under Lease Agreements

April 10, 2020

Thomas J. Gallagher and Dennis L. Cohen discuss the intricacies of section 467 lease agreements and the surprising and unexpected consequences.

Overview of the Federal Income Tax Consequences of Defaults and Restructurings Under Loan Agreements

April 07, 2020

Tom Gallagher and Dennis Cohen provide borrowers and lenders with some of the significant tax issues presented by attempts to restructure and renegotiate debtor/creditor relationships, whether by modifying the terms of the economic arrangement or restructuring the arrangement in its entirety.

Summary and Analysis of Key Provisions of the CARES Act

March 28, 2020

Members of Cozen O'Connor's Coronavirus Task Force provide analysis of the CARES Act and how it will impact small businesses, distressed industries, employers and employees, taxes, and the health care, real estates, and energy industries.

IRS Proposes Regulations Implementing Certain Parts of the Rules for Qualified Opportunity Zone Funds [White Paper]

October 31, 2018

Tom Gallagher discusses the proposed regulations, highlighting those rules that should be important to investors and sponsors of QOZ investments, and points out several key areas under the proposed regulations where guidance is lacking and where the absence of guidance could create obstacles to successfully implementing investments in a QOZ.

New Tax Bill May Require Real Estate Professionals to Rethink Long-Held Tax Truths [Tax Alert]

January 22, 2018

Tom Gallagher discusses how the Tax Cuts and Jobs Act may impact real estate professionals.

Tax Changes Affecting Real Estate Investments [Manufactured Housing Alert]

January 11, 2018

Tom Gallagher discusses the Tax Cuts and Jobs Act and its impact on the real estate industry.

New Deduction for Passthrough Entity Owners: Complexities and Planning Opportunities Abound [Tax Alert]

January 09, 2018

Thomas Gallagher discusses changes made by Section 11011 of the Act, which added new Code Section 199A that creates a tax benefit to owners of passthrough entity businesses, i.e., partnerships and limited liability companies not taxed as corporations, S corporations, and sole proprietorships.

Events & Seminars

Past Events

Third Annual NYU Real Estate Symposium

April 23, 2014 - New York, New York

Codification of Economic Substance

April 26, 2011 - Philadelphia, PA

Education

  • University of Pennsylvania Law School, J.D., cum laude, 1977
  • University of Pennsylvania, B.A., magna cum laude, 1974
  • University of Pennsylvania, B.S., magna cum laude, 1974

Awards & Honors

Chambers & Partners USA, 2020-2021

2019 Tax Lawyer of the Year in Philadelphia by Best Lawyers in America

Best Lawyers in America 1993-2022

Pennsylvania Super Lawyers 2004-2008, 2010-2013, 2015-2018

 

  • District of Columbia
  • Pennsylvania
  • Alexandria Bar Association
  • Pennsylvania Bar Association
  • Philadelphia Bar Association