Cole handles tax aspects of domestic and international matters for corporations, partnerships and high net worth individuals. He represents clients in all phases of tax disputes, from audit to IRS appeals to litigation. In his transactions practice, he has advised foreign issuers in their initial public offerings (IPO) of publicly-traded MLP [master limited partnership] interests.
His clients span a number of industries, including oil and gas exploration and production, offshore drilling, private equity funds, domestic and foreign manufacturing, shipping, real estate and medical devices. Cole has represented multinational corporations in developing and implementing transfer pricing strategies and disputing proposed transfer pricing adjustments in IRS appeals and US Tax Court. His experience includes providing tax advice on Seadrill Partners’ $220 million IPO; Seadrill Partners’ $380 million second equity offering; and KNOT Offshore Partners’ $180 million IPO.
