Proposed Regulations Under §385 Classifying Interests in a Corporation

International Journal (BNA)
July.13.2016

On April 4, 2016, the Internal Revenue Service and U.S. Treasury Department issued proposed regulations designed to curb the ability of large multinational companies to reduce their U.S. taxable income by engaging in "earnings stripping" practices (the "Proposed Regulations").

Authors

Peter Connors Partner, Tax, Corporate Tax

New York

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Finance Sector
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Corporate Tax
International Tax
Renewable Energy
Restructuring
Swaps and Other Hedges
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Peter Connors Partner

New York

According to Chambers, his peers state that Peter is “an outstanding international tax practitioner” who is admired for the strength of his activity in the field of cross-border transactions and is ”an excellent lawyer who has a diverse practice.” According to Legal 500, “Peter Connors is well-versed in terms of the taxation of financial products and financial institutions.”

Peter serves as President of the USA Branch of the International Fiscal Association. From 2020 to 2021, he was President of the American College of Tax Counsel. He now serves as chair of the College’s Amicus Brief Committee and on the ABA Tax Section’s Distinguished Service Award Committee.

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

A prolific author, with over 150 published articles on tax-related subjects, Peter is considered a thought leader in the field of taxation. He is co-author of T.M. Portfolio 543 -2d (”The Mark to Market Rules of Section 475") and the author of T.M. Portfolio 909-3d (”The Branch-Related Taxes of Section 884 “).

He has been recognized by every edition of Best Lawyers in America since 2015.

Related Areas

Tax
Finance