BERWIN COhEN
OF COUNSEL
Berwin Cohen has more than thirteen years of experience representing domestic and foreign clients and focuses his practice on U.S. and international tax planning, compliance and, when necessary, disputes and litigation with the Internal Revenue Service. Berwin’s clients include start-ups as well as major businesses headquartered abroad or in the U.S.; U.S. for profit and not-for-profit entities; and high net worth individuals.
Berwin advises investors, financial institutions and both new and old economy companies regarding the tax implications of capital raising, formation, operation, restructuring and dissolution of U.S. companies, joint ventures and strategic alliances, mergers and acquisitions, divestitures and stock and asset sales.
Berwin also counsels entities and employees on the tax implications of compensation arrangements.
Berwin also advises on the tax withholding and reporting implications of cross-border financial transactions and the holdings of foreign assets and bank accounts by U.S. tax residents.
Berwin also advises European and Latin American financial institutions and investment funds on the implementation of comprehensive compliance programs to meet the requirements of the Foreign Account Tax Compliance Act (FATCA) and day-to-day operational questions regarding FATCA reporting and withholding.
Berwin is an adjunct professor in the New York Law School L.L.M. Taxation Program. His course portfolio includes: Business Planning for the Closely Held Enterprise, Taxation of Banks and Financial Institutions, Advanced Tax Litigation Seminar, and Tax Practice & Procedure. The courses examine capital structures, entity choices, tax strategies and tax compliance procedures.
Prior to joining Reiss+Co., Berwin was the Director of a structured finance department in the New York office of Bank of Tokyo-Mitsubishi UFJ, Ltd. Prior to that he was a Senior Tax Associate at Mayer Brown LLP (in Palo Alto and New York), and before that he was Assistant Vice President and Counsel at Credit Suisse (New York). He started his career as Counsel in the New York office of Donaldson, Lufkin & Jenrette.
Practice Areas
International Taxation (Planning, Compliance and Litigation)
Education
New York University, School of Law, LL.M. (Taxation), 2002
New York Law School, J.D., cum laude, Articles Editor (Journal of International and Comparative Law), 1999
Ramapo College, B.A. (College Honors), summa cum laude, Sigma Tau Delta (honors society), 1996
Bar Admissions
California
New York
U.S. Court of Federal Claims
U.S. Tax Court
Licenses
Financial Industry Regulatory Authority (“FINRA”) Series 63 and 79
Publications
Co-Author, Protecting a Public Company’s Confidences (NLCPI 2005) (examination of attorney-client privilege challenges in wake of new public auditing standards)
Ghost-Author, The New School of Audit Effectiveness (CCH 2003) (evaluation of strategies, tools and administrative techniques of the IRS LMSB division)
Lectures
In addition to his responsibilities at the New York Law School LL.M. Taxation Program, Berwin has guest lectured at other universities, including:
Westmoreland College: Cognitive Challenges to FRE Hearsay (December 2009 and November 2010) (analysis of psychological flaws of Federal Rules of Evidence hearsay exceptions)
Stanford University: Commercial Law of Intellectual Property (October 2006 and 2007) (comprehensive survey of intellectual property taxation)
Other Interests
Berwin is the CEO of Interfint, Inc., a company that provides solutions for the management of data related to international financial transactions, technology, regulation and tax laws. Interfint’s leading product is GTIEX, a global tax information exchange cloud platform for financial institutions, governments and revenue authorities addressing FATCA and other international tax disclosure and transparency directives.