Cross-Border Flips and Inversions - Navigating the Tax Risks

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.

Laurent Olléon Partner

Paris

Laurent intervenes alongside his clients with legal and financial issues, both in terms of advice and litigation situations perspective.

Laurent deals with numerous issues in various fields: the tax consolidation system and, more generally, intra-group relations, the handling of bilateral tax treaties, the taxation of financial transactions, property taxation and local taxation, etc.

His recognized experience in the avoidance of abuse of rights enables corporate tax directors, financial investors and individuals to better secure their investment choices and structuring their transactions. In addition, his intimate knowledge of tax litigation is a major asset for clients.

Laurent has advised many ministries and public institutions on legislative and regulatory developments and their implementation, which gives him an extensive practical vision of both public and private law. His past experience has allowed him to manage and draft legislative bills, which makes him an authority on administrative and parliamentary machinery.

Before joining Orrick, Laurent was a judge of the Conseil d’État and assessor at the Court’s ninth Chamber of the litigation section of the Conseil d’État, worked as deputy Chief of staff of Marylise Lebranchu, the French Minister for the Civil Service, State Reform and Decentralisation and Chief of staff of Anne-Marie Escoffier, Deputy Minister of Decentralisation.

Jonathan Rosen Partner

London

Jonathan leads the London Tax team, and his practice is both transactional and advisory. He has extensive experience of UK, cross-border and international tax matters across a variety of business sectors, with a particular focus on Technology & Innovation, Energy & Infrastructure, and Finance.

Jonathan is qualified as a Chartered Tax Adviser (CTA) and is a member of the Chartered Institute of Taxation.

Dr. Stefan Schultes-Schnitzlein Partner

Düsseldorf

Er berät Mandanten aus der Industrie, dem Private-Equity- sowie dem Banksektor in allen Fragen des deutschen Steuer- und Bilanzrechts. Im Fokus stehen dabei Unternehmenstransaktionen sowie deren Finanzierung, finanzielle Restrukturierungen sowie Betriebsprüfungen und Steuerstreitverfahren. 

Die steuerliche Betreuung von Wachstumsunternehmen in allen Phasen ist in den letzten fünf Jahren ein immer größerer Teil seiner Arbeit geworden. U.S.-Flips, Management-Incentivierung, Finanzierungsrunden, Exits und SPAC-Transaktionen sind nur einige der Bereiche, in denen Stefan Schultes-Schnitzlein im Wachstumsbereich tätig war. 

Stefan Schultes-Schnitzlein trat zum Jahresanfang 2014 nach langjähriger Tätigkeit für internationale Rechtsanwaltskanzleien in unsere Sozietät ein.