Cross-Border Flips and Inversions - Navigating the Tax Risks

12:00pm - 1:00pm EDT / 5:00pm - 6:00pm BST / 6:00pm - 7:00pm CEST

Webinar | October.20.2021 | 12pm - 1pm (Eastern Daylight Time)

Webinar

We are increasingly seeing companies changing their residency or holding company jurisdiction, either as part of a capital raise or a tax planning strategy. These changes raise difficult tax issues which are further complicated in light of contemplated tax law changes in the United States and elsewhere. Tax partners from Orrick's French, German, Italian, U.K., and U.S. offices will discuss these issues in a virtual roundtable format.

CLE Credits Available: Y

740

Practice:

  • Finance Sector
  • Fiscale
  • Imposta sui redditi d'impresa
  • Tassazione internazionale
  • Renewable Energy
  • Restructuring
  • Swap e altri derivati
  • Contenzioso fiscale
  • Blockchain and Virtual Currency

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.

Practice:

  • Finance Sector
  • Fiscale
  • Contenzioso fiscale

Laurent Olléon Partner

Parigi

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.

Practice:

  • Fiscale
  • Imposta sui redditi d'impresa
  • Tassazione internazionale
  • Mergers and Acquisitions
  • Capital Markets
  • Banking & Finance
  • Private Equity
  • Funds
  • Energy
  • Petrolio e carburanti
  • Restructuring
  • Technology Companies Group
  • Structured Finance
  • Fintech

Jonathan Rosen Partner

Londra

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.

Practice:

  • Finance Sector
  • Fiscale
  • Imposta sui redditi d'impresa
  • International Trade and Investment
  • Contenzioso fiscale
  • Patrimonio privato
  • Tassazione internazionale

Dr. Stefan Schultes-Schnitzlein Partner

Düsseldorf

He advises industry clients, private equity funds and financial institutions on all sorts of German tax and accounting issues. Stefan's focus lies on corporate transactions, financings and re-financings and restructurings as well as on tax field audits and tax litigation in connection with any of the former. He also advises individual persons on succession and related issues.

In the last five years, tax work for growth companies at all stages has become an ever-increasing part of his work. U.S. flips, management incentivization, financing rounds, exits and SPAC transactions are only some of the areas in which Stefan has been involved in the growth space.

Prior to his move to Orrick in the beginning of 2014, Stefan has been with international law firms for eight years.