Patrick M. Cox is a partner in Baker McKenzie's New York office. He has extensive experience in general tax planning, including corporate, partnership, international and real estate taxation.
Since 2007, Mr. Cox has assisted over 30 pro bono clients in obtaining tax-exempt status for US federal income tax purposes, as well as advised foreign charitable organizations on their activities in the US.
Mr. Cox assists in developing effective tax strategies for complex cross-border and domestic business transactions. He represents local and international firms, investors and financial intermediaries in federal income tax matters related to capital market transactions and M&A. He also advises corporations and consolidated groups on the tax consequences of debt offerings, exchanges and reorganizations. He has considerable experience in advising companies, equity owners and creditors regarding the tax aspects of financial restructurings.
Representative Legal Matters
- Developed structures for US and non-US clients in connection with inbound and outbound investments in securities and real estate, including the utilization of international tax treaties.
- Assisted several multinational public companies in global rationalizations of their capital structure and intellectual property utilization.
- Counseled various clients regarding FATCA and FBAR compliance issues.
- Represented C corporations, S corporations, LLCs, partnerships and individuals before various taxing authorities in federal, state and local tax assessments.
- Served as lead tax lawyer for creditors in the Satelites Mexicanos, S.A. de C.V. reorganization, and organized a foreign investment structure to utilize tax treaty benefits and minimize Mexican and US taxes for certain fund investors. This transaction was nominated as International/Cross-Border Deal of the Year by The M&A Advisor.
- Served as tax counsel to numerous official and ad hoc committees of unsecured creditors for Lyondell, Six Flags, Visteon Corporation, Tropicana Entertainment, Delta Airlines Inc., Calpine Corporation, WorldCom Inc. and Kaiser Aluminum. He advised on tax attribute preservation, and tax structuring for the reorganization and sale of assets and equity.
- Advised on financial restructuring for various companies, including GSI Group Inc., Haights Cross Communications Inc., Eddie Bauer and Granite Broadcasting; assisted in the bankruptcy process, coordinating with creditors and financial advisors to evaluate tax issues, including the preservation and valuation of tax attributes.
Professional Associations and Memberships
- American Bar Association
- New York State Bar Association - Member of Bankruptcy and Operating Losses Committee
- New York State Bar Association - Member of Inbound U.S. Activities of Foreign Taxpayers Committee
- New York State Bar Association - Member of Outbound U.S. Activities of Foreign Taxpayers Committee
- New York State Bar Association - Member of Cross Border Capital Markets Committee
- U.S. District Court, Southern District of New York~United States (2014)
- U.S. District Court, Eastern District of New York~United States (2014)
- U.S. Tax Court (2009)
- New York~United States (1997)
- New York University School of Law (LL.M.)
- Hofstra University (J.D.)
- University of California (B.A.)
Co-author, "Fraudulent Tax Returns and the Statute of Limitations," WealthManagement.com, March 2016
Contributing editor, Chapter 7, "Federal Income Tax Issues," Collier Guide to Chapter 11: Key Issues and Selected Industries, LexisNexis, 2016
Contributing editor, Chapter 50, "Tax Liens," Debtor-Creditor Law, LexisNexis, 2016
Guest, "US Treasury Changes the Game on Tax Inversions," Bloomberg TV, April 2016
Panelist, "Financially Troubled Companies / Debt Restructuring," American Bar Association 19th Annual Philadelphia Tax Conference, November 2008