Craig Cohen is a partner in Chapman's Tax Department. He advises clients on a broad range of substantive US tax issues, such as the taxation of capital markets transactions (including securitizations, structured finance and derivatives); cross-border financing; the formation and operation of private equity, real estate and hedge funds; and FATCA. In addition, Craig has frequently addressed issues related to the creation of a US trade or business for non-US persons, rules related to the Foreign Investment in Real Property Tax Act, the application of the original issue discount rules, withholding tax issues, debt/equity characterization, partnership audit issues, partnership allocations, treaty interpretation and constructive ownership.
- Co-Author, "IRS Lowers Cash Limitation Percentage for RICs and REITs," Client Alert. May 15, 2020
- Co-Author, "Impact on REMICs and Investment Trusts of COVID-19 Forbearances on Certain Mortgage Loans," Client Alert. April 16, 2020
- Co-Author, "Business Tax Provisions in the CARES Act," Client Alert. April 9, 2020
- Co-Author, "New Proposed Regulations Take the Bite out of Section 956 Deemed Dividends for Corporate Shareholders," Client Alert. November 30, 2018
- Author, "A Complete History of FIRPTA Reform," Journal of Taxation. May 2018
- Author, "A Complete History of FIRPTA Reform," Real Estate Taxation. Q1 2018
- Co-Author, "Deemed Dividends After the Tax Cuts and Jobs Act," Client Alert. February 13, 2018
- Co-Author, “Impact of New Tax Law on Securitization Transactions,” Client Alert. December 21, 2017
- Co-Author, "IRS Blesses Stock Dividends from Certain RICs and REITs," Real Estate Finance Journal. Fall 2017
- Co-Author, “Proposed Registered Form Regulations Change Scope and Clarify Requirements,” Client Alert. October 6, 2017.
- Co-Author, “The Proposed Limitations on Deduction of Interest Could Change Funding Choices,” Client Alert. October 5, 2017.
- Co-Author, “FATCA Withholding in a Model 2 Jurisdiction,” Tax Notes. December 12, 2016
- Author, “FATCA Final Regulations: Definitions List,” Tax Notes International. May 20, 2013
Honors & Awards
Selected by The Legal 500 in 2017 as a "Next Generation Lawyer" in the category of International Tax