Tax

Featured Publication:

City of Philadelphia Real Estate Assessment Appeals [Alert]

The City of Philadelphia has extended the deadline for the filing of a first level review of real estate assessment appeals to October 14, 2022.

More

The Cozen O’Connor tax team has been providing sound advice to clients for decades. We serve public and private companies, joint ventures, real estate interests, high net worth individuals, and exempt organizations. In our federal tax practice, we advise clients on the tax implications of mergers and acquisitions, financings, real estate deals, entity structure, contractual arrangements, cross-border transactions, and other business arrangements. In our state and local tax practice, we provide the full range of transactional counsel and represent clients in tax controversies and litigation. On occasion, the tax team also supports client efforts to reform state and local tax statutes or regulations.

Tax is a key element of Cozen O’Connor’s transactional practice. Our tax group works in close collaboration with colleagues from corporate law, real estate, public and project finance, private client services, health law, labor and employment, and mergers and acquisitions on a full range of business matters. The firm’s culture of cross-disciplinary cooperation benefits clients enormously. Our tax advisors are involved from the start to ensure that every project is structured and carried out to achieve tax efficiency.

Cozen O’Connor’s tax lawyers provide support at inception and throughout the entire life cycle of a deal. For pure transactional lawyers, work is done at closing. But our tax attorneys provide tactical advice for as long as a business decision has tax implications, which can be several years or several decades. Having continuous tax counsel is essential because our attorneys accrue invaluable institutional knowledge over time. They learn the hot-button issues and logic of prior decisions so they can quickly assess how future changes will affect a client’s tax position.

Because every tax matter is inherently case-specific and subject to interpretation, attorneys at Cozen O’Connor carefully avoid generic solutions and reject a this-is-how-it’s-always-done mentality. For analytical purposes, we often calculate the cost of following a standard model. But that figure simply represents an opening bid. We then undertake to lawfully improve on that baseline by adding nuance and creativity. Through innovation, we are often able to reduce tax costs considerably.

An essential aspect of a strong tax practice is good communication. Because few people other than tax lawyers are fully fluent in code-speak, a good tax attorney must be able to translate the tax code into plain English, focus on core issues, and present information to clients in a manner that is at once sophisticated and comprehensible. Cozen O’Connor attorneys are able to operate at a high level using a common lexicon and are known for their candor and lack of pretense.

 

SERVICES

Mergers, Acquisitions, and Business Transactions

  • Advise clients on the tax aspects of public and private mergers, acquisitions, buyouts, and joint ventures, as well as spin-offs, liquidations, and other divestitures
  • Counsel clients on structured finance, project finance, leasing transactions, and the use of derivatives to hedge business operations and debt issuances
  • Advise clients on appropriate business structure, including general and limited partnerships, limited liability and series limited liability companies, and business trusts
  • Provide tax planning prior to incorporation or securities offerings
  • Guide the organization and syndication of private equity funds
  • Structure cross-border transactions with the goal of minimizing U.S. federal income tax consequences to non-U.S. treasurers and their owners

Real Estate

  • Advise clients on the optimal structure for real estate investments
  • Represent public real estate investment trusts in the entire gamut of tax matters, including the management of REIT income and asset tests and formation of non-publicly traded REITS
  • Counsel clients regarding securitizations, including real estate mortgage investment conduits (REMICs) and other asset securitizations
  • Advise clients with real estate investments that qualify for safe harbor protection
  • Assist with tax-free exchanges of like-minded properties

Tax-Exempt Organizations

  • Serve public charities, museums, trade associations, health care providers, veterans’ organizations, and private foundations
  • Advise on formation of non-profit corporations and charitable trusts
  • Obtain tax rulings and federal, state, and local tax exemptions
  • Counsel high net worth individuals and businesses on the advantages of establishing and operating private foundations

State and Local Tax

  • Represent clients in state and local tax controversies and litigation  
  • Advocate for legislative and regulatory changes in state and local tax codes
  • Advise clients about variations in state tax laws and perform multi-state tax analyses

Tax Compliance, Controversy, and Litigation

  • Render formal tax opinions in connection with specific transactions and obtain rulings from the Internal Revenue Service and state and local tax authorities
  • Represent clients in connection with IRS tax examinations, including before the IRS appeals branch, and in litigation before state and local taxing authorities, U.S. Tax Court, and the federal district and appeals courts

 

CLIENTS

Our Tax Practice represents a wide variety of corporate clients and individuals, including:

  • Public and private companies
  • Joint ventures
  • Real estate clients
  • High net worth individuals
  • Exempt organizations

TEAM

Cozen O’Connor’s Tax Practice is made up of exceptionally qualified practitioners, including a former chief counsel to the Pennsylvania Department of Revenue. Several attorneys are certified public accountants and have master’s degrees in taxation law. Our most seasoned attorneys are leading scholars in the field and have authored or edited widely referenced treatises on state tax law and real estate tax.

The firm differentiates itself, in part, through its staffing model. In plain terms, we do not believe clients are best served by sprawling teams of undermanaged associates. While we have the capacity to add support as necessary, at Cozen O’Connor tax matters are primarily handled by experienced tax professionals who are deeply knowledgeable about the relevant subject area and have credibility with judges and counterparts. Because veteran attorneys are fully cognizant of the details of every matter, they are prepared to engage in peer-to-peer dialogue with clients at any time. When clients call at 3 a.m., they don’t just get a response – they get an answer.

Experience

Publications

City of Philadelphia Real Estate Assessment Appeals [Alert]

September 20, 2022

The City of Philadelphia has extended the deadline for the filing of a first level review of real estate assessment appeals to October 14, 2022.

Pennsylvania Enacts Record Tax Reform [Alert]

July 26, 2022

Pennsylvania’s 2022-2023 budget, Act of Jul. 8, 2022, implements sweeping tax reform and revises some of Pennsylvania’s most business-unfriendly tax provisions.

Philadelphia City Councilmember Introduces Bill To Impose Wealth Tax on Stocks and Bonds [Alert]

April 05, 2022

Joe Hill, Joe Bright, and Brianna Westbrooks discuss Councilmember Brooks' proposed tax on certain intangible property, including direct holdings in stocks and bonds, at 0.4 percent.

House Ways and Means Committee Proposes Reduction of QSBS Exclusion [Alert]

September 27, 2021

Nathan Rudy and Rich Silpe discuss the draft tax legislation that was released as part of the “Build Back Better” budget reconciliation program and how it may impact the Section 1202 gain exclusion on the sale of qualified small business stock in a C corporation.

2021 Could Increase Uniformity of Taxation of Real Estate in Pennsylvania

January 27, 2021

Joe Bright and Heidi Schwartz provide an analysis of Autozone Development Corp.’s appeal of a property tax assessment that is pending before the Pennsylvania Supreme Court.

As the Pandemic Spreads, So Does the Reach of State Nexus

December 04, 2020

Heidi Schwartz and Joe Bright co-authored an article in Bloomberg Tax addressing the reporting challenges and potential tax bills confronting employers whose employees are working from home in jurisdictions outside of the employer’s workplace during the COVID-19 pandemic.

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.

Pennsylvania Commonwealth Court Sustains Revenue’s Source Analysis

September 17, 2020

Joe Bright and Heidi Schwartz co-authored an article published in Bloomberg Tax analyzing the Pennsylvania Commonwealth Court’s recent decision in Synthes USA HQ, Inc. v. Pennsylvania.

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.

Automatic Carryforward of Prior Residential Appeals Is Not Evidence of Uniform Assessments in Pennsylvania

August 11, 2020

Joseph Bright and Bob Careless co-authored an article, published by Bloomberg Tax, analyzing a recent decision by the Commonwealth Court of Pennsylvania that is favorable to commercial taxpayers facing selective reverse assessment appeals. Bright and Careless note that decision in the case, Colonial School District v. Metroplex West Associates, L.P., undercuts a common argument by localities in relying on the automatic carryforward of residential appeals when defending against claims of uniformity clause violations.

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.

Real Estate Tax Appeals [Alert]

April 30, 2020

Joe Bright advises real estate owners to consider filing an appeal of the assessed values assigned to properties for the tax year 2021.

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.

Transitioning for the End of LIBOR [Alert]

February 24, 2020

Benjamin A. Bomrind, Anne M. Madonia, and Joshua C. Weinberger discuss this discontinuation of LIBOR and how clients should prepare.

2019 Year-End Tax Update

December 20, 2019

Dennis Cohen is back for one last humorous look at all things Tax Law from 2019.

INSIGHT: Event Tickets Not Taxable to Pennsylvania Casinos [Bloomberg Tax]

November 12, 2019

Heidi Schwartz and Bob Careless explain how a court found that tickets are an intangible property deductible under the state’s gaming tax in a Bloomberg Tax article.

INSIGHT: ‘Kaestner’ Opens Door for Challenges to State Taxation of Trust Income [Bloomberg Tax]

October 15, 2019

Heidi Schwartz and Joe Bright explain the U.S. Supreme Court’s ruling in N.C. Dep’t of Revenue v. Kimberley Rice Kaestner 1992 Family Trust, holding that a state cannot tax income from an out-of-state trust based solely on the beneficiaries' residence in the state.

2018 Year-End Tax Update

December 11, 2018

Dennis Cohen takes a humorous (or as humorous as tax attorneys get) look at tax law developments from 2018.

Royalty Fees Not Subject to Pennsylvania Sales Tax [Alert]

November 29, 2018

Joseph C. Bright and Heidi R. Schwartz discuss Downs Racing, LP v. Commonwealth and the court's decision that royalty fees are intangible legal rights that do not fall within the meaning of corporeal personal property or canned software.

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.

Business Deductions Up In Smoke [Cannabis Alert]

October 11, 2018

Heidi Schwartz and Richard Silpe discuss three cases published this past summer that provide guidance to cannabis businesses and their owners in preparing their federal income tax returns. These cases turn on the application of IRC Section 280E, which precludes taxpayers from deducting any expense relating to a business that consists of trafficking in cannabis.

Pennsylvania Refund Request Untimely [Tax Alert]

September 18, 2018

Joseph Bright discusses the Pennsylvania Commonwealth Court dismissal of a taxpayer’s petition that requested reversal of an order of the Board of Finance and Revenue in Greenwood Gaming & Entertainment Inc. v. Commonwealth

Philadelphia Soda Tax Survives [Tax Alert]

August 01, 2018

Joseph Bright discusses the decision in Williams v. City of Philadelphia holding that whether a city tax is preempted under the Sterling Act will depend on the incidence of the tax — that is, on what or whom the tax is imposed.

Wayfair Decided – E-commerce Subject to Use Tax Collection [Tax Alert]

June 27, 2018

Dan Schulder discusses the 5-4 Supreme Court ruling that out-of-state online retailers can be held responsible for collecting use tax from their customers without having a physical presence in the state.

Insight: Wholesaler of Electricity Is Subject to Gross Receipts Tax [Bloomberg Law]

May 24, 2018

Joseph Bright, a member of Cozen O'Connor's Tax Practice Group, wrote an article for Bloomberg Law discussing the Pennsylvania Commonwealth Court recently ruling that an electric wholesaler is subject to the state's gross receipts tax

Update on Tax Cases from the Commonwealth of Pennsylvania [Tax Alert]

February 22, 2018

Joe Bright discusses recent decisions by the Commonwealth Court that will impact Pennsylvania taxpayers.

New Pennsylvania Personal Income Tax Withholding Requirements [Tax Alert]

February 05, 2018

Cheryl A. Upham and Heidi R. Schwartz discuss new Personal Income Tax withholding obligations on certain lessees of non-residential real property and non-employer payors of Pennsylvania source compensation and business income.

Tax Update: Big Changes in the Estate and Gift Tax Laws Require Attention

January 22, 2018

Robert Friedman and Alexia Fishman discuss important changes to the estate and gift tax rules that likely will have an impact on your estate plan.

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.

Federal Tax Reform: Major Changes Impacting Public Utilities [Utility, Environmental & Energy Alert]

January 10, 2018

David Zambito, Ira Megdal, Rich Silpe, and Rory Moore discuss the Tax Cuts and Jobs Act and the changes to the taxation of business enterprises that have significant implications for public utilities.

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.

Unnoticed Provision of New Tax Bill Makes Sex Harassment Settlements Subject to NDAs Not Deductible [Labor & Employment Alert]

January 08, 2018

Sarah Kelly, Kate Ericsson and Rory Moore discuss a provision in the new Tax Act proposed by Senator Robert Menendez, (D-N.J.) that bars deductions for settlement payments, including attorney’s fees, related to sexual harassment or sexual abuse if the settlement payment is subject to a nondisclosure agreement.

Federal Tax Legislation: Major Changes to International Taxation [Tax Alert]

January 04, 2018

Josh Weinberger discusses how the Trump administration's Tax Cuts and Jobs Act impacts U.S. persons with foreign income earned by foreign corporations.

Tax Reform Provisions Affecting Exempt Organizations [Tax Alert]

January 03, 2018

Dennis Cohen continues the firm's series summarizing the Tax Cuts and Jobs Act, specifically focusing on changes to the tax code that impact exempt organizations.

Flat Dollar Minimum on Pennsylvania Net Loss Carryover Deduction Held Unconstitutional [Bloomberg BNA]

December 27, 2017

Joseph Bright and Heidi Schwartz, members of Cozen O’Connor’s Tax Practice Group, discuss the Nextel Communications of the Mid-Atlantic, Inc. v. Commonwealth case in Bloomberg BNA.

Federal Tax Reform: Major Changes Impacting Businesses [Tax Alert]

December 21, 2017

Rich Silpe, co-chair of Cozen O'Connor's Tax Group, discusses key business tax changes under the Tax Cuts and Jobs Act. This is the first in a series of Alerts that our firm will be issuing on select topics of the Act.

2017 Year-End Tax Update [The Year in Review]

December 14, 2017

Dennis Cohen takes a humorous (or as humorous as tax attorneys get) look at tax law developments from 2017.

Freight Broker Is Not Entitled to Deduct Freight Delivery Charges [Bloomberg BNA]

November 16, 2017

Joe Bright and Bob Careless, members of Cozen O’Connor’s Tax Practice Group, discuss the Pennsylvania Commonwealth Court’s decision that a freight broker, who was taxed on delivery charges although it did not provide delivery services, does not fall within the freight delivery exception of the Local Tax Enabling Act (LTEA) in Bloomberg BNA.

Department Bound by its Own Regulation [Bloomberg BNA]

October 03, 2017

Joseph Bright and Heidi Schwartz, members of Cozen O’Connor’s Tax Practice, discuss the Saturday Family L.P. v. Commonwealth case in Bloomberg BNA, in which the Commonwealth Court en banc held that Pennsylvania Realty Transfer Tax could not be imposed on a ground lease that contained an option for renewal at fair rental value that included an appraisal procedure.

Events & Seminars

Past Events

Corporate Tax Update

November 09, 2021 - Webinar

Pennsylvania State Tax Updates

November 18, 2020 -

What the Stimulus Means for Your Company

March 31, 2020 - Webinar

2019 Brindisi Tax Academy

June 28, 2019 - Wayne, PA

The Way Forward After Wayfair

May 29, 2019 - Philadelphia, PA

PICPA South Central Chapter Annual Tax Conference

December 15, 2017 - Hershey, PA

In The News

City of Philadelphia Real Estate Assessment Appeals [Alert]

September 20, 2022

The City of Philadelphia has extended the deadline for the filing of a first level review of real estate assessment appeals to October 14, 2022.

Cozen O’Connor Adds Veteran Tax Attorney Kevin Zimka to Canadian Tax Group

September 19, 2022

Cozen O’Connor announced veteran corporate tax attorney Kevin Zimka has joined its Vancouver office as a Shareholder.

The Devil Is in the Details When Handling NFTs and State Taxes

August 30, 2022

Joseph Bright, Cheryl Upham, and Heidi Schwartz address how there is a lack of guidance when dealing with non-fungible tokens (NFTs) and what we expect from the states moving forward in Bloomberg Tax.

Six Cozen O’Connor Lawyers Named 2023 “Lawyers of the Year” by Best Lawyers

August 22, 2022

Geoffrey Ferrer, James Forsyth, J. Bruce Maffeo, Suzanne Mayes, Jason Shargel, and Anna Wermuth received the highest annual ratings from their peers.

Pennsylvania Enacts Record Tax Reform [Alert]

July 26, 2022

Pennsylvania’s 2022-2023 budget, Act of Jul. 8, 2022, implements sweeping tax reform and revises some of Pennsylvania’s most business-unfriendly tax provisions.

Chambers Ranks 86 Cozen O’Connor Lawyers, 22 Practice Areas in Chambers USA 2022 Guide

June 02, 2022

Chambers USA, the leading annual guide to the top lawyers and law firms in the United States, has ranked 86 Cozen O’Connor lawyers as leaders in their respective fields in the guide’s 2022 edition.

49 Cozen O'Connor Attorneys Named Pennsylvania Super Lawyers and Rising Stars

June 01, 2022

Super Lawyers has selected 49 Cozen O'Connor attorneys to the 2022 Pennsylvania Super Lawyers and Rising Stars lists.

Philadelphia City Councilmember Introduces Bill To Impose Wealth Tax on Stocks and Bonds [Alert]

April 05, 2022

Joe Hill, Joe Bright, and Brianna Westbrooks discuss Councilmember Brooks' proposed tax on certain intangible property, including direct holdings in stocks and bonds, at 0.4 percent.

Cozen O’Connor Recognized as a “Best Law Firm” in 29 Practice Areas Nationwide, 121 Practice Areas Regionally

November 04, 2021

U.S. News & World Report and Best Lawyers recognized Cozen O’Connor as a “Best Law Firm” in 29 practice areas nationwide and 121 practice areas regionally.

House Ways and Means Committee Proposes Reduction of QSBS Exclusion [Alert]

September 27, 2021

Nathan Rudy and Rich Silpe discuss the draft tax legislation that was released as part of the “Build Back Better” budget reconciliation program and how it may impact the Section 1202 gain exclusion on the sale of qualified small business stock in a C corporation.

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.

2021 Could Increase Uniformity of Taxation of Real Estate in Pennsylvania

January 27, 2021

Joe Bright and Heidi Schwartz provide an analysis of Autozone Development Corp.’s appeal of a property tax assessment that is pending before the Pennsylvania Supreme Court.

As the Pandemic Spreads, So Does the Reach of State Nexus

December 04, 2020

Heidi Schwartz and Joe Bright co-authored an article in Bloomberg Tax addressing the reporting challenges and potential tax bills confronting employers whose employees are working from home in jurisdictions outside of the employer’s workplace during the COVID-19 pandemic.

Cozen O’Connor Recognized as a “Best Law Firm” in 25 Practice Areas Nationwide, 115 Practice Areas Regionally

November 05, 2020

U.S. News & World Report and Best Lawyers recognized Cozen O’Connor as a “Best Law Firm” in 25 practice areas nationwide and 115 practice areas regionally.

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.

Pennsylvania Commonwealth Court Sustains Revenue’s Source Analysis

September 17, 2020

Joe Bright and Heidi Schwartz co-authored an article published in Bloomberg Tax analyzing the Pennsylvania Commonwealth Court’s recent decision in Synthes USA HQ, Inc. v. Pennsylvania.

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.

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).

Automatic Carryforward of Prior Residential Appeals Is Not Evidence of Uniform Assessments in Pennsylvania

August 11, 2020

Joseph Bright and Bob Careless co-authored an article, published by Bloomberg Tax, analyzing a recent decision by the Commonwealth Court of Pennsylvania that is favorable to commercial taxpayers facing selective reverse assessment appeals. Bright and Careless note that decision in the case, Colonial School District v. Metroplex West Associates, L.P., undercuts a common argument by localities in relying on the automatic carryforward of residential appeals when defending against claims of uniformity clause violations.

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.

Cozen O’Connor Guides Utz Quality Foods in Business Combination Agreement with Collier Creek Holdings to Form Utz Brands, Inc.

June 10, 2020

Transaction Results in Utz Going Public After Nearly 100 Years as Family Business.

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.

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.

Real Estate Tax Appeals [Alert]

April 30, 2020

Joe Bright advises real estate owners to consider filing an appeal of the assessed values assigned to properties for the tax year 2021.

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.

Transitioning for the End of LIBOR [Alert]

February 24, 2020

Benjamin A. Bomrind, Anne M. Madonia, and Joshua C. Weinberger discuss this discontinuation of LIBOR and how clients should prepare.

2019 Year-End Tax Update

December 20, 2019

Dennis Cohen is back for one last humorous look at all things Tax Law from 2019.

INSIGHT: Event Tickets Not Taxable to Pennsylvania Casinos [Bloomberg Tax]

November 12, 2019

Heidi Schwartz and Bob Careless explain how a court found that tickets are an intangible property deductible under the state’s gaming tax in a Bloomberg Tax article.

Cozen O’Connor Recognized As a Best Law Firm in 24 Practice Areas Nationwide, 106 Practice Areas Regionally

November 05, 2019

The U.S. News – Best Lawyers “Best Law Firms” rankings are based on a rigorous evaluation process that includes the collection of client and lawyer evaluations and peer review from leading attorneys in their field.

INSIGHT: ‘Kaestner’ Opens Door for Challenges to State Taxation of Trust Income [Bloomberg Tax]

October 15, 2019

Heidi Schwartz and Joe Bright explain the U.S. Supreme Court’s ruling in N.C. Dep’t of Revenue v. Kimberley Rice Kaestner 1992 Family Trust, holding that a state cannot tax income from an out-of-state trust based solely on the beneficiaries' residence in the state.

Cozen O’Connor Deepens its Corporate Practice Group Bench With Addition of Veteran Tax Attorney Christopher W. Compton

September 10, 2019

Cozen O’Connor welcomed Christopher W. Compton — a seasoned tax attorney who has served as legal counsel on a range of tax-exempt bond transactions worth (cumulatively) in excess of $2 billion — to its Corporate Practice Group.

Six Cozen O’Connor Lawyers Named 2020 “Lawyers of the Year” By Best Lawyers in America

August 28, 2019

Cozen O’Connor is proud to announce that six of the firm’s lawyers have been recognized as “Lawyers of the Year” in their respective practices by Best Lawyers in America.

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.

57 Cozen O’Connor Lawyers, 16 Practices Earn Top Recognition in Chambers USA 2019 Guide

April 25, 2019

Chambers USA, the leading annual guide to the top lawyers and law firms in the USA, has ranked 57 Cozen O’Connor lawyers as leaders in their respective fields in the Guide’s 2019 edition.

2018 Year-End Tax Update

December 11, 2018

Dennis Cohen takes a humorous (or as humorous as tax attorneys get) look at tax law developments from 2018.

Royalty Fees Not Subject to Pennsylvania Sales Tax [Alert]

November 29, 2018

Joseph C. Bright and Heidi R. Schwartz discuss Downs Racing, LP v. Commonwealth and the court's decision that royalty fees are intangible legal rights that do not fall within the meaning of corporeal personal property or canned software.

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.

Business Deductions Up In Smoke [Cannabis Alert]

October 11, 2018

Heidi Schwartz and Richard Silpe discuss three cases published this past summer that provide guidance to cannabis businesses and their owners in preparing their federal income tax returns. These cases turn on the application of IRC Section 280E, which precludes taxpayers from deducting any expense relating to a business that consists of trafficking in cannabis.

MLB's Pitch to IRS: Let Us in on Tax Law's New Break

October 10, 2018

Dennis Cohen, co-chair of the firm’s Tax Practice, discusses Major League Baseball’s opposition to a tax regulation that would deny sports franchises a deduction in The Wall Street Journal.

Pennsylvania Refund Request Untimely [Tax Alert]

September 18, 2018

Joseph Bright discusses the Pennsylvania Commonwealth Court dismissal of a taxpayer’s petition that requested reversal of an order of the Board of Finance and Revenue in Greenwood Gaming & Entertainment Inc. v. Commonwealth

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.

165,000 Philly homeowners may be paying too much in property taxes. Is the city assessing property fairly?

August 10, 2018

Joseph Bright, a member of the firm’s Tax Practice, discusses the inaccurate assessment of home values in Philadelphia an article in The Philadelphia Inquirer.

INSIGHT: Attack on E-Cigarette Tax Succeeds in Part

August 02, 2018

Joseph Bright, a member of Cozen O’Connor’s Tax Practice, authored an article in Bloomberg Daily Tax Report: State on The Pennsylvania Commonwealth Court’s ruling that the Pennsylvania Department of Revenue can tax electronic cigarettes as tobacco products.

Philadelphia Soda Tax Survives [Tax Alert]

August 01, 2018

Joseph Bright discusses the decision in Williams v. City of Philadelphia holding that whether a city tax is preempted under the Sterling Act will depend on the incidence of the tax — that is, on what or whom the tax is imposed.

Wayfair Decided – E-commerce Subject to Use Tax Collection [Tax Alert]

June 27, 2018

Dan Schulder discusses the 5-4 Supreme Court ruling that out-of-state online retailers can be held responsible for collecting use tax from their customers without having a physical presence in the state.

U.S. Supreme Court: E-commerce Subject to Use Tax Collection

June 26, 2018

Dan Schulder, a member of Cozen O'Connor’s Tax Practice, authored in the article “U.S. Supreme Court: E-commerce Subject to Use Tax Collection,” in CPA Now, a Pennsylvania Institute of Certified Public Accountants publication.

Insight: Wholesaler of Electricity Is Subject to Gross Receipts Tax [Bloomberg Law]

May 24, 2018

Joseph Bright, a member of Cozen O'Connor's Tax Practice Group, wrote an article for Bloomberg Law discussing the Pennsylvania Commonwealth Court recently ruling that an electric wholesaler is subject to the state's gross receipts tax

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.

Update on Tax Cases from the Commonwealth of Pennsylvania [Tax Alert]

February 22, 2018

Joe Bright discusses recent decisions by the Commonwealth Court that will impact Pennsylvania taxpayers.

Corporate Tax Attorney Joins Pittsburgh Office

February 05, 2018

Forsyth is the 30th Buchanan, Ingersoll & Rooney PC Attorney to Join the Firm in the Past Year and 20th Attorney to Join the Pittsburgh Office

New Pennsylvania Personal Income Tax Withholding Requirements [Tax Alert]

February 05, 2018

Cheryl A. Upham and Heidi R. Schwartz discuss new Personal Income Tax withholding obligations on certain lessees of non-residential real property and non-employer payors of Pennsylvania source compensation and business income.

2018 U.S. News & World Report – Best Lawyers "Best Law Firms" Ranks Cozen O’Connor

February 01, 2018

In the 2018 U.S. News - Best Lawyers® "Best Law Firms, Cozen O’Connor is ranked nationally in 17 practice areas and regionally in 64 practice areas.

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 Update: Big Changes in the Estate and Gift Tax Laws Require Attention

January 22, 2018

Robert Friedman and Alexia Fishman discuss important changes to the estate and gift tax rules that likely will have an impact on your estate plan.

Federal Tax Reform: Major Changes Impacting Public Utilities [Utility, Environmental & Energy Alert]

January 10, 2018

David Zambito, Ira Megdal, Rich Silpe, and Rory Moore discuss the Tax Cuts and Jobs Act and the changes to the taxation of business enterprises that have significant implications for public utilities.

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.

Unnoticed Provision of New Tax Bill Makes Sex Harassment Settlements Subject to NDAs Not Deductible [Labor & Employment Alert]

January 08, 2018

Sarah Kelly, Kate Ericsson and Rory Moore discuss a provision in the new Tax Act proposed by Senator Robert Menendez, (D-N.J.) that bars deductions for settlement payments, including attorney’s fees, related to sexual harassment or sexual abuse if the settlement payment is subject to a nondisclosure agreement.

Federal Tax Legislation: Major Changes to International Taxation [Tax Alert]

January 04, 2018

Josh Weinberger discusses how the Trump administration's Tax Cuts and Jobs Act impacts U.S. persons with foreign income earned by foreign corporations.

Tax Reform Provisions Affecting Exempt Organizations [Tax Alert]

January 03, 2018

Dennis Cohen continues the firm's series summarizing the Tax Cuts and Jobs Act, specifically focusing on changes to the tax code that impact exempt organizations.

Flat Dollar Minimum on Pennsylvania Net Loss Carryover Deduction Held Unconstitutional [Bloomberg BNA]

December 27, 2017

Joseph Bright and Heidi Schwartz, members of Cozen O’Connor’s Tax Practice Group, discuss the Nextel Communications of the Mid-Atlantic, Inc. v. Commonwealth case in Bloomberg BNA.

Federal Tax Reform: Major Changes Impacting Businesses [Tax Alert]

December 21, 2017

Rich Silpe, co-chair of Cozen O'Connor's Tax Group, discusses key business tax changes under the Tax Cuts and Jobs Act. This is the first in a series of Alerts that our firm will be issuing on select topics of the Act.

2017 Year-End Tax Update [The Year in Review]

December 14, 2017

Dennis Cohen takes a humorous (or as humorous as tax attorneys get) look at tax law developments from 2017.

Freight Broker Is Not Entitled to Deduct Freight Delivery Charges [Bloomberg BNA]

November 16, 2017

Joe Bright and Bob Careless, members of Cozen O’Connor’s Tax Practice Group, discuss the Pennsylvania Commonwealth Court’s decision that a freight broker, who was taxed on delivery charges although it did not provide delivery services, does not fall within the freight delivery exception of the Local Tax Enabling Act (LTEA) in Bloomberg BNA.

Department Bound by its Own Regulation [Bloomberg BNA]

October 03, 2017

Joseph Bright and Heidi Schwartz, members of Cozen O’Connor’s Tax Practice, discuss the Saturday Family L.P. v. Commonwealth case in Bloomberg BNA, in which the Commonwealth Court en banc held that Pennsylvania Realty Transfer Tax could not be imposed on a ground lease that contained an option for renewal at fair rental value that included an appraisal procedure.

Contacts

Richard J. Silpe

Chair, Tax

rsilpe@cozen.com

(215) 665-2704

Cheryl A. Upham

Vice Chair, Tax

cupham@cozen.com

(215) 665-4193

People

Awards

Chambers Ranks 86 Cozen O’Connor Lawyers, 22 Practice Areas in Chambers USA 2022 Guide

June 02, 2022

Chambers USA, the leading annual guide to the top lawyers and law firms in the United States, has ranked 86 Cozen O’Connor lawyers as leaders in their respective fields in the guide’s 2022 edition.

49 Cozen O'Connor Attorneys Named Pennsylvania Super Lawyers and Rising Stars

June 01, 2022

Super Lawyers has selected 49 Cozen O'Connor attorneys to the 2022 Pennsylvania Super Lawyers and Rising Stars lists.

Cozen O’Connor Recognized as a “Best Law Firm” in 29 Practice Areas Nationwide, 121 Practice Areas Regionally

November 04, 2021

U.S. News & World Report and Best Lawyers recognized Cozen O’Connor as a “Best Law Firm” in 29 practice areas nationwide and 121 practice areas regionally.

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.

Cozen O’Connor Recognized as a “Best Law Firm” in 25 Practice Areas Nationwide, 115 Practice Areas Regionally

November 05, 2020

U.S. News & World Report and Best Lawyers recognized Cozen O’Connor as a “Best Law Firm” in 25 practice areas nationwide and 115 practice areas regionally.

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.

Cozen O’Connor Recognized As a Best Law Firm in 24 Practice Areas Nationwide, 106 Practice Areas Regionally

November 05, 2019

The U.S. News – Best Lawyers “Best Law Firms” rankings are based on a rigorous evaluation process that includes the collection of client and lawyer evaluations and peer review from leading attorneys in their field.

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.

Six Cozen O’Connor Lawyers Named 2020 “Lawyers of the Year” By Best Lawyers in America

August 28, 2019

Cozen O’Connor is proud to announce that six of the firm’s lawyers have been recognized as “Lawyers of the Year” in their respective practices by Best Lawyers in America.

57 Cozen O’Connor Lawyers, 16 Practices Earn Top Recognition in Chambers USA 2019 Guide

April 25, 2019

Chambers USA, the leading annual guide to the top lawyers and law firms in the USA, has ranked 57 Cozen O’Connor lawyers as leaders in their respective fields in the Guide’s 2019 edition.

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.

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