Mr. Cope’s experience includes advising on tax matters related to transfer pricing and the taxation of income from intellectual property, structuring tax-efficient corporate acquisitions and divestitures for US multinationals and funds, arranging cross-border financings and tax-efficient business expansions and restructurings, and identifying and managing U.S. trade or business and permanent establishment issues encountered by non-U.S. persons with a U.S. tax presence. He has worked with multinational enterprises headquartered in the U.S., Europe, and Asia in a variety of industries, including technology, manufacturing, services and shipping. He has extensive experience interpreting U.S. income tax treaties.
Prior to joining A&M, Mr. Cope carried on his own tax practice, advising U.S. and non-U.S. clients on U.S.-international tax matters. Previously, he spent 15 years as a Principal in KPMG’s Washington National Tax Office.
Early in his career, Mr. Cope worked as an attorney in the US Treasury’s Office of Tax Policy. In that role he participated in the drafting of U.S. income tax regulations and the 1996 U.S. Model Income Tax Convention as well as the negotiation of US income tax treaties. He was also the US representative to Working Party 1 of the OECD’s Committee on Fiscal Affairs dealing with the OECD’s Model Tax Convention on Income and on Capital.
Mr. Cope earned a bachelor’s degree in economics (cum laude) from Rice University and a master’s degree in economics from the University of Chicago. He also earned a J.D. from the University of Chicago Law School and an LLM in taxation from New York University Law School. Mr. Cope is a member of the New York and District of Columbia bars.
Mr. Cope has published articles on U.S. cross-border tax matters in the Journal of Taxation, TAXES – The Tax Magazine, Tax Notes International, and the Tax Management International Journal. He also volunteers as the president of the International Tax Institute, a New York not-for-profit corporation offering educational webinars to attorneys and CPAs on recent developments in US international taxation.
