91ÊÓƵ

ACADEMIC AND PROFESSIONAL ENGAGEMENT ACTIVITIES

Professor Philip G. Cohen is a retired Vice President-Tax & General Tax Counsel for Unilever United States, Inc. having worked in the corporate tax function at Unilever for over 26 years including the last 10 ½ years as head of the U.S. based tax department. He practiced corporate tax law for 33 years and was an adjunct professor at 91ÊÓƵ Lubin School of Business for 23 years before joining the full-time faculty in 2012.

Professor Cohen is an active member of the American Bar Association and its Tax Section, the New York State Bar Association and its Tax Section and is now an Associate Member of Tax Executives Institute (TEI) and its NYC Chapter after serving for many years, while functioning as a corporate tax executive, as a member and chair of many of its committees and task forces including having chaired the Federal Tax Committee; Communications Committee; Tax Reform Task Force; Tax Shelter Task Force; and Financial Products Subcommittee He regularly attends conferences of the NY State Bar Association –Tax Section and Tax Executives Institute –NYC Chapter and serves on two subcommittees of the NYS Bar Association –Tax Section. Professor Cohen is the author of numerous op-eds on tax related subjects in addition to his scholarly writings.

LLM, New York University School of Law, NYC
Taxation

LLM, New York University, New York, NY
Labor Law

JD, Duke University, Durham NC

MBA, George Washington University, Washington D.C.
Accounting; Admitted to Beta Gamma Sigma Honor Society

BA, New York University, New York, NY
Political Science; With Honors

SELECTED CONTRIBUTIONS & PUBLICATIONS

Cohen, P.G. (2025) Expensing vs. Capitalization of Patent Infringement Costs Associated with FDA Approval of Generic Drug Manufacturers - Reflections on Mylan Inc. & Subsidiaries v. Commissioner. . Virginia Tax Review, Winter 2025

Cohen, P.G. (2024). Blocked Income & 3M Company & Subsidiaries v. Commissioner-Round One- The Chevron Step One Argument. The Tax Lawyer. 77 (Winter 2024), 351-356.

Cohen, P. (2023). Whirlpool Financial Corp. v. Commissioner Was Properly Decided. The Tax Lawyer. 76 (Winter 2023), 247-292.

Cohen, P.G. (2022). Thoughts Regarding the Application of the Step Transaction Doctrine to the Section 351 Control Requirement and Complex Media v. Commissioner. William & Mary Business Law Review. 13(2).

Cohen, P.G. (2021). Zarin v. Commissioner Revisited and Some Methodologies for Determining COD Income. William & Mary Business Law Review. 12(3), 537-619.

Cohen, P. (2020). The Political Question Doctrine: An Inappropriate Roadblock to the Limitation on Benefits Safety Valve. Houston Business and Tax Law Journal. XXI(1).

Cohen, P. (2019). Capital Contributions of Limited License Rights to Intellectual Property Under Section 351. Houston Business and Tax Law Journal. (Spring 2019).

Cohen, P. (2019). The Compulsory Tax Constraint for Foreign Tax Credits Post TCJA & Coca-Cola Co. v. Commissioner. The Tax Lawyer. (Winter 2019).

Cohen, P.G. (2018). The Fact of the Liability in the All Events Test- Flying Lessons over the Dark Clouds of General Dynamics from a Giant Eagle. The Tax Lawyer. 71 ( Spring 2018), 635-672.

Cohen, P. (2017). Statutory Interpretation Lessons Courtesy of Pilgrim's Pride. University of Miami Business Law Review. 25 (2017; Issue 3).

Cohen, P.G. (2016). The Long(v.Commissioner) and Short of the Substitute for Ordinary Income Doctrine. Pittsburgh Tax Review. 13 (Spring 2016).

Cohen, P.G. (2015). The Origin of the Claim Doctrine and Litigation Expenses with a Connection to Property Transactions-Woodward and Hilton Hotels Post Ash Grove Cement. Houston Business and Tax Law Journal. XV(I), 1-54.

Cohen, P. (2014). "Testing for Thin Capitalization Under Section 163(j) - A Flawed Safe Harbor". The Tax Lawyer. 67 (Issue 1; Fall 2013).

Cohen, P. (2013). Personal Goodwill: Possible Escape from Double Taxation and More. Tax Notes. 140(13), 1427-1438.

Cohen, P. (2012). "The Sourcing of Goodwill". Corporate Taxation. 39 (number 4 September-October 2012).

Cohen, P. (1995). "Schleier Requires Congress to Clarify When Damages Received for Discrimination are Not Taxable". . 47

Cohen, P. (1985). "Capital Gains and the Relinquishment of Contract Rights". . 63

Cohen, P. (1982). "Capital Gains and the Sale of Know-How". . 82(August 1982).