Mr. Cohen provides strategic advice to clients about the tax aspects of structuring the formation, acquisition, disposition, operation, and liquidation of businesses. His experience extends to a variety of industries, including oil and gas, manufacturing, healthcare, and real estate. He focuses counseling on renewable energy and low-income housing tax credit projects.
Mr. Cohen provides advice to a number of funds focused on investing in various sectors of the economy, including hedge funds, venture capital funds, oil and gas funds, and real estate funds. This advice has included fund structuring for U.S. investors, tax-exempt investors and foreign investors; disclosure of tax issues to potential investors and investment structuring. He also assists master limited partnerships (MLPs) with acquisitions, offerings, drop-downs and qualifying income issues.
Mr. Cohen has been asked to speak around the country in the fields of renewable energy tax incentives, partnerships, reportable transactions, and tax-exempt entities. In addition, he is a columnist for the Journal of Passthrough Entities and chairs Holland & Hart's Income Tax Group.
Salman Ranch v. United States (Fed. Cir.) — In this case, the Federal Circuit held that an overstatement of basis does not constitute an omission from gross income and therefore does not warrant application of the six year statute of limitations.