COZART.COM

Toby Cozart

Mr Cozart is a tax lawyer practicing in a small firm, Piedmont Law Partners, with offices in the San. Francisco Bay Area. He specializes primarily in:. Domestic and Cross-Border Lease and Project Financing. And Limited Liability Companies. International Leasing Joint Ventures. In recent years, he has advised clients about tax-advantaged lease and partnership alternatives for renewable energy financings. See Lease vs P'ship. Published by the Bureau of National Affairs in its Tax Management Portfolio serie...

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Toby Cozart | cozart.com Reviews

<META> DESCRIPTION

Mr Cozart is a tax lawyer practicing in a small firm, Piedmont Law Partners, with offices in the San. Francisco Bay Area. He specializes primarily in:. Domestic and Cross-Border Lease and Project Financing. And Limited Liability Companies. International Leasing Joint Ventures. In recent years, he has advised clients about tax-advantaged lease and partnership alternatives for renewable energy financings. See Lease vs P'ship. Published by the Bureau of National Affairs in its Tax Management Portfolio serie...

<META> KEYWORDS

1 us income

2 tax law

3 t oby

4 c ozart

5 attorney at law

6 partnerships

7 and leasing partnership

8 and p'ship modeling

9 his background

10 site home

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us income,tax law,t oby,c ozart,attorney at law,partnerships,and leasing partnership,and p'ship modeling,his background,site home,financing expertise,expert witness,innovative ideas,lease modeling,pship modeling,publications,background,contact me

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Toby Cozart | cozart.com Reviews

https://cozart.com

Mr Cozart is a tax lawyer practicing in a small firm, Piedmont Law Partners, with offices in the San. Francisco Bay Area. He specializes primarily in:. Domestic and Cross-Border Lease and Project Financing. And Limited Liability Companies. International Leasing Joint Ventures. In recent years, he has advised clients about tax-advantaged lease and partnership alternatives for renewable energy financings. See Lease vs P'ship. Published by the Bureau of National Affairs in its Tax Management Portfolio serie...

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cozart.com

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Lease Modeling

http://www.cozart.com/lease_pricing_expertise.htm

Since the mid 1990’s, Mr. Cozart has modeled a variety of lease transactions using leading software programs for pricing leasing and partnership transactions. He has focused extensively on partnership leasing structures, joined together with the latest techniques for satisfying the rental income accounting rules under IRC 467, including rent loans. He has also developed models to confirm the assumptions used in pricing. New and restructured conventional lease transactions. In the typical big-ticket lever...

2

Tax-Exempt Lessee

http://www.cozart.com/tax-exempt_entity_leasing.htm

Since 1984, Mr. Cozart has been involved in the development and analysis of transactions designed to enhance the tax depreciation of property leased to tax-exempt lessees. He. Developed a unique structure for operating lease transactions that was used to finance a fleet of railcars in the U.S. This strategy has been limited by the enactment of IRC 470 in 2004, which requires tax losses from property leased to tax-exempt lessees to be suspended and carried forward against income from the property.

3

Innovative Ideas

http://www.cozart.com/new_structures.htm

The US. government has aggressively attacked tax shelters on audit, and enacted legislation and promulgated regulations that require their registration and disclosure. While innovative transactions risk eliciting an adverse governmental response, taxpayers who engage in legitimate business activity should (and inevitably will) continue to seek out and employ innovative tax-reducing strategies. The question is w.

4

Publications

http://www.cozart.com/publications.htm

BNA Tax Management Portfolio, 545 T.M., Equipment Lease Characterization. 1st ed. 1996; 2nd ed. 2009, forthcoming). Comprehensive analysis of when a transaction involving the use of property constitutes a sham, lease, loan, partnership, service contract or estate for years for U.S. federal income tax purposes. Disputing Rev. Rul. 99-14: Pre-Tax Profit, Defeasance, and Circular Leases,. 83 Tax Notes 557-571 (April 26, 1999).

5

Expert Witness

http://www.cozart.com/LILO_expert.htm

Expert Witness in LILO Tax Litigation. Mr Cozart has served as an expert witness for the taxpayer in one of the litigated cases. He submitted an expert report that explains the factual basis for recognition of the various allegedly offsetting and circular components of the transaction. He has also assisted the taxpayer in evaluating the government's arguments. Mr Cozart discussed the issues involving LILO transactions in detail in his leasing treatise and an article published in 1999. See Publications.

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Mr Cozart is a tax lawyer practicing in a small firm, Piedmont Law Partners, with offices in the San. Francisco Bay Area. He specializes primarily in:. Domestic and Cross-Border Lease and Project Financing. And Limited Liability Companies. International Leasing Joint Ventures. In recent years, he has advised clients about tax-advantaged lease and partnership alternatives for renewable energy financings. See Lease vs P'ship. Published by the Bureau of National Affairs in its Tax Management Portfolio serie...

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