U.S. Income
Tax Law

Toby Cozart 

Attorney at Law         


Selected Employment Background

KPMG LLP
San Francisco, California, Director, Stratecon
April 2003 – March 2000
Responsible for structured leasing transactions within western states’ division of the firm’s high-end corporate solutions group.

HOSIE, WES, SACKS & BRELSFORD, LLP
San Francisco, California, Of Counsel (Tax)
September 1998 – October 1995
Equipment leasing transactions; venture capital financings; corporate acquisitions; S corporations, partnerships and limited liability companies; financial instruments. (The firm has since merged with Perkins Coie.)

JACKSON, TUFTS, COLE & BLACK
San Francisco, California, Of Counsel (Tax)
May 1995 – January 1991
Equipment financings, including like-kind exchanges, rent strips, alternative energy project financings and international double-dip and commission FSC leasing transactions; cross-border and domestic equipment leasing, real estate and manufacturing partnerships; controlled foreign corporations; corporate acquisitions, reorganizations and divisions involving public and private (including “S”) corporations; dual consolidated losses; unrelated business income tax; financial instruments, including foreign currency, options and REMICs. (The firm ceased conducting business in the late 1990s.)

GATX CAPITAL CORPORATION
San Francisco, California, Tax Counsel
December 1990 – October 1988
Equipment financings, including project financings, international double-dip and commission and leasing FSC transactions; portfolio lease and leasing company acquisitions and dispositions; cross-border and domestic equipment leasing partnerships; real estate development limited partnerships; and offshore loan participation funds.

MORGAN, LEWIS & BOCKIUS
New York, New York, Tax Associate
November 1985 –September 1981
General corporate taxation, with major emphasis on equipment and real estate financings and divisive and acquisitive reorganizations; partnership taxation, including real estate syndications and builder-bond financings; and international taxation, particularly of foreign investments in the U.S., foreign reorganizations, DISCs and FSCs, and foreign trusts.

U.S. HOUSE OF REPRESENTATIVES
Washington, D.C.
Committee on Ways and Means, Oversight Subcommittee, Assistant Staff Counsel
August 1980 – December 1978

 

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