Toby Cozart is a tax lawyer who specializes in domestic and cross-border project and lease financing, partnerships and limited liability companies and international joint ventures. In recent years, he has advised clients about tax-advantaged lease and partnership transactions for renewable energy financings. He has broad experience representing individuals and corporations in a variety of other tax and related legal matters, including controversies with the Internal Revenue Service. He practices law with a small firm, Piedmont Law Partners, with offices in the San Francisco Bay Area. He has held positions as a director for a Big 4 accounting firm, tax counsel for a major U.S. leasing company, tax partner at a major west coast law firm, and staff counsel for a U.S. Congressional subcommittee.
Education:
LL.M. in Taxation, New York University School of Law (1981)
M.S. in Philosophy, University of North Carolina (1979)
J.D., Duke University (1978)
B.A., University of North Carolina (1974)
Tax Management Portfolios™
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Equipment Leasing: Substance and Form (Portfolio 544)
This Portfolio summarizes basic lease transactions, the reasons for leasing, various factors that have affected lease structures and the sources of legal principles governing tax lease characterization.
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Equipment Leasing: Benefits and Burdens (Portfolio 545)
This Portfolio discusses the factors to consider when establishing an equipment leasing arrangement to assure that it will be treated as a lease for U.S. federal income tax purposes.