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Introduction
Patrick Cox is a partner in Nixon Peabody’s M&A and Corporate Transactions Practice Group and member of the Tax team. He focuses on various tax aspects facing domestic and international companies and has significant experience in areas of capital markets, reorganizations, real estate, and private equity matters.
My focus
Corporate and Transactional Tax Matters
I focus my practice on developing tax strategies for complex cross-border and domestic business transactions. I represent local and international firms, investors, and financial intermediaries in federal income tax matters related to capital market transactions and M&A.
I have extensive experience in advising clients on inbound and outbound tax issues relating to investment in securities and real estate, IP rationalizations, tax treaty planning, and tax issues related to banking and finance, as well as creditor tax issues, including debt offerings, exchanges, and reorganizations, including bankruptcy.
Looking ahead
The upcoming sunset of many of the provisions of the Tax Cuts and Jobs Act of 2017, many of which expire after 2025, and the tax policy objectives of the incoming Administration and Congress, require attention and provide significant planning opportunities. The post-Chevron tax planning related to Internal Revenue Service guidance allows me to add value to companies and investors when dealing with such guidance in a wide array of areas, including during the winding down of the employee retention tax credit and other COVID-19–era tax policies.
In the news
- Law360
Navigating the last leg of the worker retention tax credit
Oct 23, 2024New York City Corporate partner Rick Cox, a member of NP’s Tax team, Albany Government Investigations & White-Collar Defense partner Tina Sciocchetti, and Boston Complex Disputes partner Morgan Nighan contributed this article, discussing the several recent and significant developments affecting the employee retention credit, a tax credit established by the CARES Act in response to the COVID-19 pandemic.
- Think Advisor
How a new Supreme Court ruling could affect business owner clients
June 11, 2024This article covers the impact of the recent US Supreme Court ruling in Connelly v. United States. The article references and quotes from a Nixon Peabody alert on the ruling, written by New York City Corporate partner and Tax team member Rick Cox and Private Clients associates Stephanie Ardino of New York City and Joshua Caswell of Boston. Rick, Stephanie, and Joshua discuss how clients and their advisors should recognize that succession planning decisions could affect other arrangements.
- Bloomberg Tax
Businesses face tricky choice on IRS program for Covid credit
March 22, 2024New York City Corporate partner and Tax team member Rick Cox is quoted in this article, which covers the March 22 voluntary disclosure deadline for businesses that received Employee Retention Tax Credit (ERC) refunds, but ultimately may have been ineligible under terms of the ERC program.
- Rochester Business Journal
A word of caution to those employers that claimed the Employee Retention Tax Credit
Nov 10, 2023This article covers the IRS suspending the processing of employee retention tax credit (ERC) claims, and what that means for employers. New York City Corporate partner and Tax team member Rick Cox, Boston Complex Disputes partner Morgan Nighan, and Rochester Complex Disputes counsel Eric Ferrante contributed this article.
- Bloomberg Tax
Net operating losses—policies, effectiveness, and alternatives
This article contributed by New York City corporate partner Rick Cox, Washington, DC corporate associate Brian Kenney, and Washington, DC. Complex Disputes associate Myra Benjamin, explains how taxpayers can take advantage of net operating loss (NOL) deductions to offset taxable income in other tax years, and whether NOL policy is effective or if there are better alternatives.May 31, 2022 - Power Finance & Risk
DIF fund to buy Oklahoma wind farm
June 9, 2021This article mentions NP for advising DIF Capital Partners’ infrastructure fund on its agreement to acquire the Kingfisher wind farm in Oklahoma. The deal team includes Washington, DC Community Development Finance partner Shariff Barakat, Rochester Corporate partner Lori Green, Buffalo Global Finance partner Martha Anderson, and Rochester Corporate associate Aya Hoffman.
Also contributing to the deal were New York City Corporate partner Rick Cox; Manchester partner Mark Beaudoin and San Francisco partner Alison Torbitt, both of the Affordable Housing & Real Estate group; and Washington, DC partners Elizabeth Whittle and Bob Daileader and counsel Ken Weiner, all of the Project Finance & Public Finance group.
- Cannabis Business Executive
The Cannabis industry should employ careful tax planning when allocating between cost of goods sold and ordinary business expenses
Corporate partner and Tax team member Rick Cox and Corporate associate Vince Tennant, both of the New York City office, contributed this article on careful tax planning for cannabis companies, which are denied certain business expenses since cannabis remains illegal at the federal level.May 9, 2021 - The Well News
"Devil is in the details" of corporate tax reform
This article on the Biden administration’s proposal for domestic and global corporate tax reform quotes New York City Corporate partner Rick Cox, a member of the Tax team, on concerns related to a minimum tax, how the revenue threshold has shifted since Biden’s presidential campaign, and possible implications for companies that recently decided to expand globally.April 9, 2021 - Law360
4 Consideration for Investing in Opportunity Zones
New York City Corporate partner Rick Cox provides commentary in this article about how managers of qualified opportunity funds can minimize conflicts of interest through organizational documents.Feb 19, 2020 - Reuters Legal
Lawyers on the move
This roundup of key personnel moves in the legal industry features the arrival of New York City Corporate partner Rick Cox to Nixon Peabody.Sep 25, 2019 - Bloomberg Law News
US Law Week
This roundup of executive news highlights the arrival of Corporate partner Rick Cox in the firm’s New York City office.Sep 24, 2019 - Mergers & Acquisitions
M&A Wrap
This roundup of executive news highlights the arrival of Corporate partner Rick Cox in the firm’s New York City office.Sep 24, 2019 - The Deal
Movers & Shakers
This roundup of executive news highlights the arrival of Corporate partner Rick Cox in the firm’s New York City office.Sep 24, 2019
Admitted to practice
New York
U.S. District Court, Southern District of New York
U.S. District Court, Northern District of New York
U.S. Tax Court
Maine
Tennessee
Education
New York University School of Law, LL.M.
Hofstra University, J.D.
University of California, Berkeley, B.A.
Recognition
Rick has been recognized for exceptional client service by Martindale-Hubbell as a recipient of their 2020 “Client Champion” award.
