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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, private equity investments and controversy matters.

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 serves as Vice President 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

    • Representation of UNUM in connection with implementation of U.S.-U.K. sale-repurchase transaction.
    • Representation of ING in connection with implementation of U.S.-Luxembourg sale- repurchase transaction.
    • Representation of Matlin-Patterson in connection with investment in Huntsman Chemicals.
    • Representation of Alabama Retirement Fund in connection with its investment in U.S. Air.
    • Representation of First Marblehead in connection with sale of assets.
    • Representation of public company in connection with IRS controversy.
    • Representation of company in connection with Tax Court proceeding.
    • Provide disclosure and opinions to European-based issuer on its registered structured note program.
    • Provide advice to European-based financial institution on proprietary option transactions.
    • Provide structuring advice to private equity group in connection with formation of Kenyan company.
    • Representation of numerous Asian companies in connection with 144A transactions listed on Hong Kong Stock Exchange.
    • Representation of U.S. insurance company in connection with implementation of FATCA.
    • Representation of Naturex in connection with acquisition of Natraceuticals Group worldwide assets.
    • Representation of Naturex in connection with acquisition of Decas.
    • Representation of numerous individuals in connection with Offshore Account Voluntary Disclosure submissions.
    • Representation of Dover Corporation in connection with Competent Authority proceeding.
    • Representation of W.W. Grainger in connection with intellectual property restructuring initiative.
    • Representation of Solarlytics in connection with worldwide restructuring of intellectual property.
    • Representation of Carestream Dental in connection with intellectual property realignment following spin off from Carestream Health.
    • 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.
    • 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.

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