Attorney at Law         

International Leasing Joint Ventures

Since the 1980’s, Mr. Cozart has advised clients about how to structure international joint ventures for investments in plant and equipment to obtain optimum tax treatments in various countries, including the United States.

In the early 1990’s, he advised a client in the formation of a major offshore (U.S.) aircraft leasing company and worked with investors from the European Community, Japan and the United States to create a unique structure for the company.  This company secured the use of favorable withholding tax rates on rents under various international tax treaties.  Some other examples of his work include offshore leasing transactions for aircraft components and cargo container fleets.

These transactions typically involve various tax considerations:

• Utilization of tax losses by U.S. investors, including under the dual consolidated loss regulations and partnership tax allocation regulations;

• Utilization of U.S. tax credits by U.S. investors, particularly relating to partnership allocations and structures that raise economic substance considerations;

• Avoidance of adverse U.S. tax treatment resulting from foreign currency gains and losses;

• Minimization of U.S. taxes imposed on foreign investors who do not wish to conduct business in the U.S., including taxes on U.S. source rental income under applicable bilateral tax treaties; and

• Minimization of foreign taxes imposed on foreign investors.

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