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, "Strictly Speaking: What Lenders Need to Know about Strict Foreclosure and Restructurings," Chapman and Cutler LLP, September 2020
- Co-Author, "Strictly Speaking, Part III: How Can a Lender Incentivize Management in a Strict Foreclosure?," Client Alert, July 31, 2020
- Co-Author, "Impact of COVID-19 Mortgage Loan Forbearances on REMICs and Investment Trusts," Journal of Taxation of Financial Products, July 2020
- Co-Author, "Brief Summary of Selected Tax Provisions in the CARES Act," Journal of Taxation of Financial Products, July 2020
- Co-Author, "IRS Lowers Cash Limitation Percentage for RICs and REITs," Client Alert, May 15, 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
- Panelist, "Structured Financing," 10th International Bar Association London Finance and Capital Markets Virtual Tax Conference, January 20, 2021
- Panelist, ""The Government’s COVID-19 Credit Programs: Tax Considerations for Financial Institutions," American Bar Association's Virtual 2020 Fall Tax Meeting, September 29-October 2, 2020
Honors & Awards
- Selected by The Legal 500 in 2017 as a "Next Generation Lawyer" in the category of International Tax
- Selected by The Legal 500 in 2014 as a "Recommended Lawyer" in the category of International Tax