Peter Connors


New York

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Peter Connors, a tax partner in the New York office, focuses his practice on cross-border transactions. He also has extensive experience in related areas of tax law, including asset securitization, financial transactions, corporate reorganizations, and private equity investments.

A significant portion of his practice involves tax controversy, including representation of taxpayers before the U.S. Tax Court. According to Chambers, he is "admired by peers for the strength of his activity in the field of cross-border transactions."

Peter is the Regent for the Second Circuit of the American College of Tax Counsel.

Before joining Orrick, Peter was a principal in the International Tax Services Group of Ernst & Young in New York.

A prolific author, Peter is a frequent lecturer for a variety of major organizations and has published more than 100 articles on tax planning subjects. He is a co-author of T.M. Portfolio 543 ("The Mark to Market Rules" of Section 475-2d) and the author of T.M. Portfolio 909-3d ("The Branch-Related Taxes" of Section 884). From 2008 to 2010, he was the Vice Chair, Committee Operations, of the American Bar Association Tax Section. In 2010, Peter also founded the NYC Calendar Program for the U.S. Tax Court.

Peter's Representative Transactions

  • Representation of UNUM in connection with implementation of U.S.-U.K. sale-repurchase transaction.
  • Representation of ING in connection with implementation of U.S.-Luxembourg sale- repurchase transaction.
  • Representation of Matlin-Patterson in connection with investment in Huntsman Chemicals.
  • Representation of Alabama Retirement Fund in connection with its investment in U.S. Air.
  • Representation of First Marblehead in connection with sale of assets.
  • Representation of public company in connection with IRS controversy.
  • Representation of company in connection with Tax Court proceeding.
  • Provide disclosure and opinions to European-based issuer on its registered structured note program.
  • Provide advice to European-based financial institution on proprietary option transactions.
  • Provide structuring advice to private equity group in connection with formation of Kenyan company.
  • Representation of numerous Asian companies in connection with 144A transactions listed on Hong Kong Stock Exchange.
  • Representation of U.S. insurance company in connection with implementation of FATCA.
  • Representation of Naturex in connection with acquisition of Natraceuticals Group worldwide assets.
  • Representation of Naturex in connection with acquisition of Decas.
  • Representation of individual in connection with Offshore Account Voluntary Disclosure submission.
  • Representation of Dover Corporation in connection with Competent Authority proceeding.

Posts by: Peter Connors

Proposed Regulations Under §385 Classifying Interests in a Corporation

Orrick attorneys authored an article, titled “Proposed Regulations Under §385 Classifying Interests in a Corporation,” addressing Section 385 regulations proposed by the Internal Revenue Service and the U.S. Treasury Department to address the excessive use of debt to reduce the U.S. tax base. The article was published in the Tax Management International Journal and is available here.

IRS Proposes to Revise the Treatment of Nonperiodic Payments

On May 8, 2015, the Internal Revenue Service (“IRS”) and the Department of the Treasury (“Treasury”) issued proposed and temporary regulations (the “Regulations”) relating to the treatment of notional principal contracts (“NPCs”) with nonperiodic payments.[1] The Regulations are designed to resolve questions that have arisen with the enactment of Dodd-Frank. The Regulations are a fundamental change in the treatment of NPCs. The rules apply to NPCs entered into on or after November 4, 2015, but taxpayers may apply the rules to NPCs entered into before November 4, 2015. The Regulations package also includes regulations under section 956 of the Internal Revenue Code of 1986 (the “Code”).

While the Regulations are designed to resolve issues, many unanswered questions remain.