IRS Reverses its Position Regarding the Treatment of Merger Breakup Fees
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