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U.S. Income Tax Law |
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Attorney at Law |
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Financing Expertise Mr. Cozart has advised a number of leading U.S. companies on the tax aspects of domestic and international leasing transactions. He is the author of a comprehensive legal treatise on the tax characterization of leasing transactions, Equipment Lease Characterization, published by the Bureau of National Affairs in its Tax Management Portfolio series (#545). He has served as inside tax counsel for a major U.S. leasing company, GATX Capital Corporation. He began his tax leasing career during the 1980s in the New York City office of Morgan Lewis & Bockius, a leading leasing law firm. He has
worked with many aspects of leasing transactions, including most
notably
These transactions include financings of property eligible for special tax treatment under the foreign sales corporation and successor provisions, synthetic GAAP leases treated as loans for tax purposes, securitized operating lease portfolios and cross-border leases eligible for tax benefits in more than one country. See the further discussions of Leasing Partnerships, Tax-Exempt Entity Leasing, International Leasing Joint Ventures and Lease versus Partnership. |
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big ticket transactions involving power plants, commercial
passenger airplanes, railcars and containers. He has structured new
lease financings, including drafting and negotiating tax indemnities
and other tax-sensitive provisions, and has restructured existing
lease transactions.