Philip R. Hirschfeld
Associatephirschfeld@coleschotz.com New York Office1325 Avenue of the Americas, 19th Floor, New York, NY 10019
T: 646-563-8955 / C: 917-763-6704 / F: 646-563-7955
Legal Practice Assistant: Veronica Marshman
T: 201-489-3000
vmarshman@coleschotz.com
OVERVIEW
Philip Hirschfeld, an associate in the Tax, Trusts & Estates Department, focuses his practice in the areas of tax planning, tax controversy and international tax planning. His practice focuses on formation, sale or restructuring of businesses (including mergers and acquisitions), real estate investments (including Qualified Opportunity Zone Funds), partnership tax planning, debt restructuring, cross border investments and planning for non-US persons coming to work or live in the US and US companies operating abroad as well as advising clients on the tax aspects of such transactions. Before joining Cole Schotz, he concentrated on foreign investment in U.S. real estate, cross-border investments by U.S. companies operating abroad, and income tax planning for high net-worth individuals at a boutique international tax law firm.
Philip is an active member of the ABA Section of Real Property, Trust and Estate Law, where he is chair of the Committee on Federal Taxation of Real Estate. He is also an active member of the ABA Section of Taxation and chair of the FATCA subcommittee of their Committee on U.S. Activities of Foreigners and Tax Treaties. He has also been appointed to the Bloomberg Tax Pass-Through Entities Advisory Board. Philip is a recipient of the Nolan Fellowship from the Section of Taxation, which recognizes leadership qualities and a commitment to the Tax Section. In addition, he is the recipient of a Fellowship from the Real Property, Trust and Estate Law Section honoring future section leaders.
He has lectured on cross border real estate investments, Qualified Opportunity Zone Funds, mergers & acquisitions, partnership tax planning and other topics for the American Bar Association, New York University, the Florida Annual Tax Institute and other groups and has authored several articles for numerous publications on cross border investments, qualified opportunity zones, recent tax legislation and other subjects.
Philip received his B.A. from New York University in Digital New Media and Urban Design & Architecture, magna cum laude in 2006, his J.D. from The George Washington University Law School in 2009, and his LL.M. in taxation from the New York University School of Law in 2013. He is admitted to practice in both New York and the District of Columbia.
Services
Education
New York University School of Law, LL.M. in Taxation, 2013The George Washington University, Law School, J.D., 2009New York University, Gallatin School of Individualized Study, B.A.magna cum laude, 2006
Bar & Court Admissions
District of Columbia, 2012 (inactive)New York, 2011U.S. District Court, Eastern District of New York, 2011U.S. District Court, Southern District of New York, 2011NEWS
News
Cole Schotz Represents J&K Ingredients Corp. ("J&K") in Acquisition by CORE Industrial Partners
October 30, 2020
CORE Industrial Partners LLC acquires J&K Ingredients Industry News CORE Industrial Partners LLC acquires J&K Ingredients
As published in: Snack Food & Wholesale Bakery October 29, 2020
121-year-old Paterson baking ingredients company is acquired by private-equity firm
As published in: ROINJ October 22, 2020
NJ's Biggest O-Zone Trades
As published in: The Real Deal August 1, 2019
Opportunity Zones One Step Away From Receiving Official Guidance Investors Are Desperately Seeking
As published in: Bisnow October 18, 2018
EVENTS
Upcoming Events
Cancelling and Modifying Mortgage, PPP and Business Debt in a COVID World
Attorney Speaking: Philip R. HirschfeldApril 22, 2021Recent Events
Opportunity Zones Take Flight – What the Latest Regulations Mean for Your Deal
Attorney Speaking: Philip R. HirschfeldSeptember 18, 20192019 NYU Federal Real Estate and Partnership Tax Conference
Attorney Speaking: Philip R. HirschfeldJune 28, 2019Webinar: Qualified Opportunity Zones (QOZ): Maximizing Impact for Clients and Community
Attorneys Speaking: Jeffrey H. Schechter and Philip R. HirschfeldFebruary 6, 2019NYU Federal Real Estate and Partnerships Tax Conference
Attorney Speaking: Philip R. HirschfeldJune 29, 2018Planning for Foreign Investment in the U.S. CLE Presentation at Cole Schotz New Jersey Office
Attorneys Speaking: Steven M. Saraisky and Philip R. HirschfeldJune 21, 2018Qualified Opportunity Zones (QOZ): Maximizing Impact for Clients and Community
Attorneys Speaking: Philip R. Hirschfeld and Jeffrey H. SchechterFebruary 6, 2019Common Cross-Border Issues in M&A and Tax Planning
Attorney Speaking: Philip R. HirschfeldAugust 2, 2017Foreign Persons Investing in US Real Estate and Other Assets: Partnership and Other Structures, Treaty Planning and Financing Strategies
Attorney Speaking: Philip R. HirschfeldJuly 20, 2017PUBLICATIONS
Publications
Carried Interests: Final Capital Gain Recharacterization Rules Released
Tax, Trust & Estates Law February 23, 2021
Philip R. HirschfeldIRS Approves SALT CapWorkaround: A HelpfulOption to Consider
Bloomberg BNA January 25, 2021
Philip R. HirschfeldNew Jersey Landmark Economic Recovery Legislation Adopted
Tax, Trust & Estates Law January 21, 2021
Philip R. HirschfeldAlert: Continuation and Expansion of the Paycheck Protection Program
Corporate Law December 24, 2020
Samantha B. Epstein, Jennifer L. Horowitz and Philip R. HirschfeldSALT CAP Workaround – An IRS Holiday Gift
Tax, Trusts & Estates Law November 23, 2020
Philip R. HirschfeldRelief for Qualified Opportunity Funds & their Investors affected by the COVID-19 Pandemic
Tax, Trust & Estates Law June 24, 2020
Philip R. HirschfeldCOVID-19 Alert: Paycheck Protection Program Flexibility Act of 2020
Corporate Law June 5, 2020
Samantha B. Epstein, Philip R. Hirschfeld, Christopher J. Kula, Jennifer L. Horowitz and Roger M. IorioCOVID-19 ALERT: Paycheck Protection Program Guide
June 4, 2020
Samantha B. Epstein, Philip R. Hirschfeld, Jennifer L. Horowitz, Roger M. Iorio and Christopher J. KulaBuyer Beware: Withholding When Purchasing Partnership Interests from Non-U.S. Persons
Bloomberg BNA May 20, 2020
Philip R. HirschfeldTax Planning in Light of Business Hardship: Cancellation of Debt Income
Tax, Trust & Estates Law April 28, 2020
Philip R. Hirschfeld and Steven M. SaraiskyTax Planning in Light of Business Hardship: Tax Relief Issues in the CARES Act
Tax, Trust & Estates Law April 28, 2020
Philip R. Hirschfeld and Steven M. SaraiskyIRS Extends Key Tax Deadlines for 1031 Tax Deferred Exchanges and Investments in Qualified Opportunity Funds
Tax, Trust & Estates Law April 16, 2020
Christopher J. Caslin, Jeffrey H. Schechter and Philip R. HirschfeldCOVID-19 Alert: Coronavirus Aid, Relief, and Economic Security Act
Corporate Law March 27, 2020
Samantha B. Epstein, Roger M. Iorio, Arnold M. Zipper, Christopher J. Kula, Brian L. Gardner, Philip R. Hirschfeld and David J. ChoyneCOVID-19 Alert: Alleviating Tax Burdens
March 20, 2020
Jeffrey H. Schechter and Philip R. HirschfeldWhat's Trending- Opportunity Zones
March 4, 2020
Jennifer L. Horowitz, Leo V. Leyva, Marc P. Press, Jeffrey H. Schechter and Philip R. HirschfeldCode §962 Election is an Option for GILTI Planning
Tax, Trust & Estates Law June 4, 2019
Steven M. Saraisky and Philip R. HirschfeldHelpful IRS Proposed Regulations Issued on Qualified Opportunity Zone Funds
Tax, Trusts & Estates Law May 2, 2019
Jeffrey H. Schechter and Philip R. HirschfeldQualified Opportunity Zone Funds: An Investment Option Worth Considering- Updated
American Bar Association May 2019
Philip R. HirschfeldQualified Opportunity Zone Funds: An Investment Option Worth Considering
American Bar Association December 11, 2018
Philip R. Hirschfeld2017 Tax Act Overview: A Helpful Hand for Most Real Estate
American Bar Association May 1, 2018
International Tax Reform: Adoption of Territorial System and GILTI Tax
Tax, Trust & Estates Law January 31, 2018
Should I be a C Corp? Choice of Entity after Tax Reform
Tax, Trust & Estates Law January 22, 2018
Tax Court holds that foreign corporation’s sale of a partnership interest not taxable in US
Tax, Trust & Estates Law August 23, 2017
Inversions Under Siege: Treasury’s Latest Countermeasures
Journal of Taxation and Regulation of Financial Institutions July, 2016
Partnership Property Contributions: The Good, The Bad and the Ugly
BNA Tax Management Real Estate Journal February, 2016
Deciphering Tax Allocation Provisions in a Partnership Agreement
Probate & Property January, 2016
Purchasing a Partnership/LLC Interest: Tax Tip #2 – Code Section 754 Election
Real Property, Trusts & Estates e-Report August, 2015
Purchasing a Partnership/LLC Interest: Tax Tip #1—Requiring Tax Distributions
Real Property, Trusts & Estates e-Report May, 2015
Foreign Investment in U.S. Real Estate-Thinking About Taxes Before Investing
Journal of Taxation of Investments Spring, 2015
FATCA 2013 Overview: Getting Down to the Wire
Journal of Taxation and Regulation of Financial Institutions March/April, 2014
FATCA Update: Navigating the Electronic Registration Portal
BNA Tax Management International Journal November 8, 2013
FATCA’s Impact on Real Estate Funds
GGI Real Estate News Summer, 2013