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



  • Finance Sector
  • Fiscalité
  • Impôts des sociétés
  • Fiscalité internationale
  • Renewable Energy
  • Restructuring
  • Swaps et autres instruments de couverture
  • Litiges en matière de fiscalité
  • Blockchain and Virtual Currency

Peter Connors Partner

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, renewable energy investments and controversy matters. He also leads the Orrick's Section 45Q practice relating to the tax credit for carbon capture and sequestration.

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.



  • White Collar, Investigations, Securities Litigation & Compliance
  • Strategic Advisory & Government Enforcement (SAGE)

Amy Walsh Partner

New York

Amy is a trusted advisor and advocate for clients who face scrutiny by government regulators and prosecutors. Ranked Band 1 in Chambers in White Collar Crime and Government Investigations, Amy leads high-stakes internal investigations, litigation, and trials for her clients. Prior to entering private practice, she was Chief of the Business and Securities Fraud Section in the U.S. Attorney’s Office for the Eastern District of New York.

Amy represents individuals and institutions in government investigations, enforcement actions and prosecutions conducted by the U.S. Department of Justice (DOJ), the Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC) and the Internal Revenue Service. She negotiates resolutions with government officials, but also tries cases against the government. She is a fierce advocate for her clients, and her work often results in the government declining to bring charges.

Amy 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 U.S. government and supervised several sections within the Office.

Amy has also served as a court-appointed monitor for a global financial institution.