Current Employment Position(s)

Partner

Lawyer Overview

David Cowling chairs the Firm's state and local tax practice and its e-commerce tax practice. His corporate, partnership, and individual tax practice includes extensive federal, state, and local income and franchise, sales and property tax audit planning, tax class action defense, and litigation experience; complex multijurisdictional individual tax and compensation planning; tax planning for the acquisition and disposition of businesses; tax planning for distressed businesses prior to, in, and emerging from bankruptcy proceedings; structuring of real estate, oil and gas, entertainment, and equipment leasing transactions; tax planning in connection with public and private securities offerings; and tax planning for a wide variety of tax-exempt bond offerings.

David is listed in the 2008 edition of The Best Lawyers in America and was selected by D Magazine as one of the "Best Lawyers in Dallas." He is a member of the BNA Tax Management State Tax Advisory Board, the CCH State Tax Advisory Board, the State Bar of Texas (Tax Section), and the District of Columbia Bar (Taxation Section).

Areas of Practice

• Tax
• Mergers & Acquisitions/Tax
• Private Equity/Tax
• State and Local Tax Controversies
• State and Local Tax Counseling
• Tax Audits & Controversies
• Bankruptcy Taxation
• International/Cross-Border Planning & Transactions
• Hospitality

Representative Cases

• 7-Eleven, Inc., f.k.a. The Southland Corporation v. Comptroller of the Treasury, No. 1661 (Md. Ct. Spec. App., June 13, 2001)  (Unreported)
• Centex vs. State of Nevada
• Electronic Data Services v. Louisiana, Nos. 4640, 4994 and 4995 (Louisiana Board of Tax Appeals)
• Home Interiors and Gifts, Inc, v. Department of Revenue, Ill.App.3d 205, 741 N.E.2d 998, (Ill. App. 1 Dist. Nov. 13, 2000) (No. 90959), appeal denied, 195 Ill.2d, 754 N.E.2d 1285 (Ill. Jun 06, 2001) (No. 90959)
• MCI v. Dallas County Education District
• The Southland Corp. v. Comptroller, State of Maryland, No. 1402 (Md. Ct. Spec. App. 1997) & No. 1661 (Md. Ct. Spec. App. 2001), cert. denied, 366 Md. 247, 783 A.2d 221 (Md. 2001); also proceedings in Md. Tax Ct. and in Md. Circuit Ct.
• Williams Power Co. v. City of Redondo Beach, LASC Case No. BS 106625
• Acquisition of Bethlehem Steel
• Acquisition of Edgington Oil Company
• Acquisition of Santa Fe Natural Tobacco
• Business process outsourcing services agreement with Genpact
• Chapter 11 Debtor Representations , (2006)
• Chapter 11 Debtor Representations
• Chapter 11 Debtor Representations
• Economic Development Incentives
• Formation of Reynolds American
• Headquarters and Data Center Facilities
• Merger with Valero Energy
• NRG Energy Exchange Offer
• Recapitalization of All-In-One Products and USA Printing & Mailing, LLC
• Sale of Core Voice and Data Business
• Sale of Eckerd
• Sale-Leaseback Transaction

West Practice Categories

Banking & Finance Law, Bankruptcy Law, Corporate Taxation, Estate & Gift Taxation, Excise Taxes, Income Taxation, International Law, International Taxation, International Taxation, International Transactions, Mergers, Acquisitions & Divestitures, Payroll Taxes, Property (Ad Valorem) Taxes, Sales & Use Taxes, State, Local & Municipal Law, Taxation Law

Bar Admissions

• District of Columbia
• New York
• Texas

Education

• U of Texas - Austin

Published Works

• Conundra on the Tundra: Will the U.S. Supreme Court Exercise Liberty and Provide Justice for all in Polar Tankers v. City of Valdez, Alaska? Jones Day State Tax Return, 2009
• New York Governor Proposes Important Tax Changes, Jones Day State Tax Return, 2009
• American Recovery and Reinvestment Tax Act of 2009: Description of Key Business Provisions, 2009
• New York Governor Proposes Important Tax Changes, 2009
• Texas Comptroller Transfers Administrative Tax, 2007
• Texas Makes More Procedural Changes To Audit and Hearing Process, Jones Day State Tax Return, 2007
• The SSTP Has Landed: Dealing With The Streamlined Sales Tax Rules, TEI Dallas Chapter, Jones Day State Tax Return, 2005
• Texas Successor Liability: Avoiding Traps for the Unwary In Purchasing Certain Assets of Companies in Bankruptcy, BNA Tax Management, Weekly State Tax Report, 2005
• Texas Successor Liability: A Trap For The Unwary, Jones Day State Tax Return, 2005
• Indiana Tax Court Once Again Rejects State's Attempt To Tax 100 Percent of U-Haul Companies' Rental Receipts, Jones Day State Tax Return, also published in BNA's Weekly State Tax Report on the Web and Multistate Tax Report, 2005
• No Indiana DOR, You Can't Have All The Cookies In The Cookie Jar -- Indiana Tax Court Once Again Rejects The Indiana DOR's Attempt To Tax 100% Of The Income Of The Indiana U-Haul Companies, Jones Day State Tax Return, 2005
• Tax Reserves, Tax Planning and Workpapers: 'Are My Tax Documents Privileged?' TEI Dallas Chapter, 2004
• Run, Here Come the Cops - Troublesome New California Anti-Tax Shelter Provisions; Recent MTC Tax Shelter Report and Activities, Jones Day State Tax Return, 2004
• Business Purpose and State Tax Shelter Legislation, TEI Dallas Chapter's Current Developments Tax Seminar, 2004
• The Wild and Wooly Year That Almost Was: The Texas Legislature Ends a Tumultuous Legislative Session with a Whimper, Jones Day State Tax Return, 2003
• The Empire Strikes Back - New York Tax Appeals Tribunal Overturns Favorable Decision in Sherwin-Williams, Holds Sherwin-Williams Responsible for Filing Combined Returns With Its Intellectual Property Holding Companies, Jones Day State Tax Return, 2003
• The E-Tax Man Cometh, 2002

Address

2727 North Harwood Street
Dallas, TX 75201-1515

Phones

1.214.969.2991 (Business Phone)

Faxes

1.214.969.5100 (Business Fax)

Emails

Contact Us (Business Email)

Websites

http://www.jonesday.com