Charles Cope

Senior Advisor
30+ years of experience in all aspects of cross-border corporate taxation
Extensive experience advising clients on complex cross-border tax issues 
New York
@alvarezmarsal
LinkedIn
Copied!
Charles W. Cope is a Senior Advisor with Alvarez & Marsal Tax in New York. He focuses on global transaction tax. Mr. Cope brings more than 30 years of experience in all aspects of cross-border corporate taxation. He has extensive experience advising clients on complex cross-border tax issues and achieving desired tax consequences while limiting tax-controversy risk.

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.

Insights By This Professional

Treasury and the IRS recently published a new set of final regulations for taxpayers that conduct business through a foreign branch or disregarded entity whose functional currency is different than that of the taxpayer.
On August 6, 2024, Treasury and the IRS released proposed regulations that address several long-standing issues related to dual consolidated losses and introduce new rules for disregarded payment losses. What are the impacts that taxpayers should consider?
On June 28, 2024, the U.S. Supreme Court issued a landmark decision in Loper Bright Enterprises v. Raimondo and Relentless v. Department of Commerce (collectively referred to as “Loper Bright”) overturning the 40-year-old Chevron doctrine (Chevron U.S.A. v. Natural Resources Defense Council Inc.).
On November 9, 2023, in a seemingly endless effort to address a daunting responsibility delegated to them back in 1986, Treasury and the IRS released a new set of proposed regulations (REG-132422-17) for determining taxable income or loss and foreign currency gain or loss with respect to a “qualified business unit” (QBU) with a different functional currency (FC) from that of its owner.
Latest insights The latest insights from Charles Cope's team
Thought Leadership
A&M experts discuss the notable changes reflected in the new exposure draft released by the Australian Government on February 12th, 2024, and further examine the governments intent to align more closely with the European Union public country-by-country reporting directive.
Contact me
FOLLOW & CONNECT WITH A&M