Peter Connors

Peter Connors

Orrick, Herrington & Sutcliffe LLP

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New Treasury Regulations Target Corporate Inversions

Last week, the Internal Revenue Service and Treasury Department announced a number of new regulations intended to make it more difficult to qualify for tax advantages associated with inversion transactions and reduce certain...more

10/3/2014 - Controlled Foreign Corporations Corporate Taxes Income Taxes Inversion Mergers Tax Benefits U.S. Treasury

Assessing Retroactive Inversion Legislation And Its Risks

The increasing use of corporate inversions, whereby a company via merger achieves 20 percent or more new ownership, claims non-U.S. residence, and is then permitted to adopt that country’s lower corporate tax structure and...more

9/11/2014 - Corporate Taxes Inversion Inverted Domestic Corporations IRC Legislative Agendas Retroactivity Senate Banking Committee U.S. Treasury

IRS Scripts a New Tune with Final Whistleblowing Regulations

Section 7623 of the Internal Revenue Code (the “Code”), added in 1954, authorizes the Treasury Secretary to pay an award as he deems necessary for “(1) detecting underpayments of tax, or (2) detecting and bringing to trial...more

9/4/2014 - Anti-Retaliation Provisions IRC IRS U.S. Treasury Whistleblower Awards Whistleblowers

New York State Corporate Tax Law Reform: The Impact on Companies Providing Digital Products

On March 31, 2014, Governor Cuomo signed into law legislation that provides for an extensive reform of the state's corporate tax regime (the "Act"), most notably for out-of-state corporations providing digital products to New...more

7/31/2014 - Corporate Taxes Digital Assets Franchise Taxes Popular State Taxes Tax Reform

IRS Issues Final Regulations and New Proposed Regulations Regarding Withholding on Derivatives on U.S. Stocks

On December 5, 2013, the Internal Revenue Service ("IRS") issued final regulations (the "Final Regulations") and proposed regulations (the "2013 Proposed Regulations") under section 871(m), which address withholding on...more

12/30/2013 - Derivatives IRS Stocks Withholding Requirements

IRS Issues Temporary Regulations on the Application of the Straddle Rules to Debt Instruments

On September 5, the IRS issued temporary regulations on the application of the straddle rules to debt instruments (the "Temporary Regulations"). The Temporary Regulations provide that a taxpayer's obligation under a debt...more

10/16/2013 - Debt Foreign Currency IRS

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