Breakfast Roundtable: Recent Developments Affecting Taxpayers and Their Representatives

Firm Event | February.12.2019 | 8:30am - 10:00am (Eastern Standard Time)

Orrick New York

A panel from Orrick's Tax Advocacy Group will discuss issues that continually permeate audits and investigations, recent developments in the law, and the new frontier of cryptocurrency.

Topics will include:

  • Tax reporting of cryptocurrency transactions in light of recent market developments and IRS announcements
  • Changes to the IRS Offshore Voluntary Disclosure Program, including alternative strategies for unreported accounts, cryptocurrency gains, related attorney-client privilege issues, and recent court decisions addressing FBAR penalties
  • A discussion of recent court decisions involving the statute of limitations for tax shelter promoters, the treatment of stock-based compensation in cost sharing arrangements, and modifications to forward contracts

The panelists are members of Orrick's Tax Advocacy Group who have decades of experience representing taxpayers and accountants in all phases of civil and criminal tax litigation, including audits, investigations, trials and appeals.

Breakfast will be served as well as one hour of CLE credit, please click below to register.

CLE Credits Available: Y

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Practice:

  • Complex Litigation & Dispute Resolution
  • Securities Litigation, Class Actions and Shareholder Derivative Lawsuits
  • Antitrust & Competition
  • Intellectual Property
  • Mass Torts & Product Liability

J. Peter Coll, Jr. Partner Complex Litigation & Dispute Resolution, Securities Litigation, Class Actions and Shareholder Derivative Lawsuits

New York

Peter Coll is a senior member of the firm's Complex Litigation & Dispute Resolution Group in New York. He served as a member of the Firm's Executive Committee from 2000 until 2012. He is known for his ability to help clients develop litigation strategies that meet both their case-specific and business objectives.

Peter has tried major, complex cases in New York state and federal courts and throughout the United States, including Washington, the Virgin Islands, California and Arizona. During his 40+ year litigation and trial career, he has argued appeals before the United States Supreme Court, the highest-level appellate courts of New York and New Jersey, and seven federal circuit courts of appeal.


Peter has represented Fortune 500 companies, such as American Cyanamid Company, The Dow Chemical Company, American Home Products Corporation, Mead Corporation, Alleghany Corporation and Schering-Plough Corporation. He has also represented privately held companies and high-profile individuals, such as Mickey Mantle and Tom Brady. Peter's cases have involved general commercial, antitrust, securities fraud, mergers and acquisitions, product liability, federal taxation, ERISA, consumer fraud and intellectual property.


He currently represents Hemlock Semiconductor Corporation in a number of suits pending in both state and federal courts in Michigan and New York seeking to recover damages (in the billions of dollars) for Hemlock under long term polycrystalline silicon contracts with both foreign and domestic buyers. He also represents DHL in its antitrust suits in the Eastern District of New York against domestic and international airlines arising out of a price fixing cartel. He recently has represented several energy producers in litigation over disputes arising out of sale and lease back transactions and option to buy disputes.


Before joining Orrick, Peter was a partner at Donovan Leisure Newton & Irvine, LLP (1976-1998), where he served as Chairman of its Executive Committee.

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Practice:

  • Tax
  • Corporate Tax
  • Restructuring
  • International Tax
  • Swaps and Other Hedges
  • Tax Advocacy
  • Japan
  • Master Limited Partnerships
  • Blockchain and Cryptocurrency

Peter Connors Partner Tax, Corporate Tax

New York

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 financial transactions, corporate reorganizations, private equity investments and controversy matters.

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 serves as Vice President 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.

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Practice:

  • White Collar, Investigations, Securities Litigation & Compliance

Amy Walsh Partner White Collar, Investigations, Securities Litigation & Compliance

New York

Amy Walsh, a partner in Orrick’s New York office, is the former Chief of the Business and Securities Fraud Section of the United States Attorney’s Office for the Eastern District of New York.

Prior to entering private practice, Ms. Walsh was an Assistant United States Attorney for 12 years in the United States Attorney’s Office for the Eastern District of New York, where she led dozens of investigations and cases on behalf of the government, and supervised several sections within the Office.

Ms. Walsh is a trusted advisor to her clients, who hire her to handle matters involving government and internal investigations.  

Throughout her time in private practice, Ms. Walsh has represented individuals and institutions in government investigations, enforcement actions, and prosecutions conducted by various government agencies including the U.S. Department of Justice, the Securities and Exchange Commission, the Commodity Futures Trading Commission and the Internal Revenue Service. Ms. Walsh litigates cases in federal and state court, negotiates with representatives of government enforcement agencies, and advises clients on compliance issues.

In addition, Ms. Walsh served as the court-appointed Independent Reviewer in JPMorgan Chase’s settlement with the United States Department of Justice, where she was responsible for ensuring JPMC’s fulfillment of its obligations under the settlement agreement and publicly reporting on JPMC’s compliance.

Ms. Walsh serves as a member of the Board of Directors of the New York Council of Defense Lawyers, and was named by Super Lawyers as one of the top 50 women lawyers in the New York metro area.
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Practice:

  • Corporate Tax
  • International Tax
  • Tax Advocacy
  • Nonprofit Organizations
  • Public Finance Tax

Stephen Lessard Senior Associate Corporate Tax, International Tax

New York

Stephen Lessard, an associate in Orrick's New York office, is a member of the Tax Group. Steve focuses his practice on the taxation of debt and equity offerings, cross-border transactions, tax controversy, and municipal finance. He also has experience counseling nonprofit organizations on federal tax law and corporate governance. 

Prior to joining Orrick, Steve was a Surface Warfare Officer in the U.S. Navy.