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Peter Connors

Partner

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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.

“[A]n 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.” - Chambers USA

  • Peter served as co-author of a report on carbon capture for the United States Energy Association and Department of Energy. The report is entitled “Review of Federal, State, and Regional Tax Strategies and Opportunities for CO2-EOR-Storage and the CCUS Value Chain.”

  • Peter's Representative Transactions

    • Representation of Waimana Hydrogen in connection with formation, collaboration agreement and Series A Preferred Stock Offering.
    • Representation of owner of carbon capture equipment in connection with joint venture with corporate investor.
    • Served as co-author of White Paper for United States Energy Association, an affiliate of the Department of Energy, on implementation of carbon capture and sequestration strategies.
    • Co-counsel on amicus briefs submitted to Supreme Court and Ninth Circuit in Altera Corp. v Commissioner.
    • Counsel of record on amicus brief on behalf of the American College of Tax Counsel submitted to the U.S. Supreme Court in Rodriquez v. FDIC involving the consequences of tax sharing agreements in bankruptcy proceedings.
    • Counsel of record on amicus brief on behalf of the American College of Tax Counsel submitted to the Fifth Circuit in Haynes v. United States regarding penalty assertion arising from the use of tax preparation software.
    • Representation of Carestream Dental in connection with intellectual property realignment following spin off from Carestream Health.
    • Representation of Solarlytics in connection with worldwide restructuring of intellectual property.
    • Representation of W.W. Grainger in connection with intellectual property restructuring initiative.
    • Representation of Dover Corporation in connection with Competent Authority proceeding.
    • Representation of numerous individuals in connection with Offshore Account Voluntary Disclosure submissions.
    • Representation of Naturex in connection with acquisition of Decas.
    • Representation of Naturex in connection with acquisition of Natraceuticals Group worldwide assets.
    • Representation of U.S. insurance company in connection with implementation of FATCA.
    • Representation of numerous Asian companies in connection with 144A transactions listed on Hong Kong Stock Exchange.
    • Provide structuring advice to private equity group in connection with formation of Kenyan company.
    • Provide advice to European-based financial institution on proprietary option transactions.
    • Provide disclosure and opinions to European-based issuer on its registered structured note program.
    • Representation of company in connection with Tax Court proceeding.
    • Representation of public company in connection with IRS controversy.
    • Representation of First Marblehead in connection with sale of assets.
    • Representation of Alabama Retirement Fund in connection with its investment in U.S. Air.
    • Representation of Matlin-Patterson in connection with investment in Huntsman Chemicals.