Cozen O’Connor: Gallagher, Thomas J.

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

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.

Sixty-Two Cozen O’Connor Lawyers Named to the Best Lawyers in America

August 15, 2016

Sixty-two Cozen O’Connor lawyers from 13 of the firm’s national offices have been selected for inclusion in the 2017 edition of The Best Lawyers in America.

Fifty-Two Cozen O’Connor Lawyers Named to the Best Lawyers in America

August 17, 2015

The current edition is based on more than five million detailed evaluations by the top lawyers of the country. This list will be included in dozens of city and regional publications in the United States including The Wall Street Journal, The New York Times, and The Washington Post.

46 Cozen O’Connor Lawyers Named to The Best Lawyers in America

August 28, 2013

Forty-six Cozen O’Connor lawyers from eight of the firm’s national offices have been selected for inclusion in The Best Lawyers in America. Attorneys were selected based on a rigorous peer-review of more than 4.3 million detailed evaluations. The list will be included in publications such as The Washington Post, Los Angeles Times, and New York magazine.

Tom Gallagher Quoted in Wall Street Journal on Ending REIT Tax Exemption

April 24, 2013

Gallagher notes, “It would be a major issue. You’ve got an entire industry … predicated on the idea that you will not have any level of tax imposed on those entities.”

43 Cozen O’Connor Lawyers Named to The Best Lawyers in America

February 09, 2011

Forty-three Cozen O’Connor lawyers from six of the firm’s national offices have been selected for inclusion in the 2011 edition of The Best Lawyers in America. Lawyers were selected for inclusion in the 2011 edition based on a rigorous peer–review of more than 3.1 million detailed evaluations.

Forty-Two Cozen O’Connor Attorneys Honored as Best Lawyers in America

September 29, 2009

Forty-two Cozen O’Connor attorneys from seven of the firm’s national offices have been selected for inclusion in the 2010 edition of The Best Lawyers in America.

Cozen O’Connor Launches Capital Markets Group Multidisciplinary Team Serves Expanding, Global Capital Markets’ Client Base

July 07, 2009

Cozen O’Connor Launches Capital Markets Group Multidisciplinary Team Serves Expanding, Global Capital Markets’ Client Base

Publications

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.

IRS Issues Guidance to Examiners on the Codified Economic Substance Doctrine and Associated Penalties [Tax Alert!]

July 21, 2011

IRS Issues Guidance to Examiners on the Codified Economic Substance Doctrine and Associated Penalties - Tax Alert! - On July 15, the IRS Large Business and International Division (LB&I) issued an Industry Director’s Directive (Directive) providing guidance to examiners and their managers regarding the Codified Economic Substance Doctrine (ES Doctrine) and its penalties. The Directive describes when it is appropriate to raise the ES Doctrine in a case and the series of steps the examiner must take to seek approval for the application of the ES Doctrine in the particular case.

Losses and Deductions From a Tax-Exempt Organization's Unrelated Trade or Business - Maximizing Tax Efficiencies in a Distressed Real Estate Market [Tax Group Reprt]

July 08, 2011

Losses and Deductions From a Tax-Exempt Organization's Unrelated Trade or Business - Maximizing Tax Efficiencies in a Distressed Real Estate Market - Tax Group Reprt - In connection with its ongoing compliance audits of colleges and universities, the Internal Revenue Service has been reviewing the extent to which colleges, universities and certain other Code Sec. 501(c)(3) organizations reported tax losses from unrelated businesses. According to news reports, the IRS believes that these losses have been used to offset taxable income realized by the organizations from unrelated trades or businesses

Fall 2010 [Business Law Observer]

November 23, 2010

Fall 2010 - Business Law Observer - Since our Spring 2010 Observer was published, significant new legislation has been enacted
by Congress, affecting tax planning and securities transactions, among other areas. We have summarized two of the new acts, in addition to a review of existing legislation as it affects doing business abroad. Imbedded in the Health Care Act is a new provision in the Internal Revenue Code, codifying the “economic substance doctrine.”

Recent IRS Guidance on the Tax Consequences of Modifications of Commercial Mortgage Loans Held by REMICs and Investment Trusts [Real Estate Alert!]

September 25, 2009

Recent IRS Guidance on the Tax Consequences of Modifications of Commercial Mortgage Loans Held by REMICs and Investment Trusts - Real Estate Alert! - On September 15, 2009, the Internal Revenue Service released important guidance dealing with modifications of commercial mortgage loans held by REMICs. The guidance comprised three separate items: (i) final regulations expanding the list of loan modifications by REMICs that do not result in the modified obligation ceasing to be a qualified mortgage loan for a REMIC, (ii) a new Revenue Procedure setting forth the conditions under the IRS will not challenge the income tax status of

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

Practice Areas

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

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

Best Lawyers in America 1993-2019

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

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