Peter Connors

Peter Connors

Orrick, Herrington & Sutcliffe LLP

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IRS and Treasury Issue Final Regulations Under §385 Classifying Interests in a Corporation

On October 13, 2016, the IRS and Treasury Department issued much anticipated regulations (the “Final” or “Temporary” Regulations) under Internal Revenue Code section 385. These regulations, which consist of both temporary...more

11/10/2016 - Bifurcation Debt Debt Instruments Expanded Group Instruments (EGIs) Financial Institutions Financial Sector Foreign Issuers IRS Multinationals Section 385 Stocks U.S. Treasury

Tax Benefit from Leveraged Partnerships Shut Down By New IRS Regulations

On October 5, 2016, the IRS and Treasury released a package of new regulations under Code sections 707 and 752 designed to curtail the use of debt to reduce tax on the contribution of appreciated assets to leveraged...more

10/11/2016 - Business Taxes Capital Gains Debt IRS MLPs Partnerships Sale of Assets Tax Liability Tax Rates U.S. Treasury

IRS Issues Proposed Regulations That Would Recast Certain Debt Instruments as Equity

On April 4, 2016, the IRS and U.S. Treasury Department, in connection with a package of anti-inversion regulations prompted by news of the recent spate of corporate inversions (particularly the $160 billion Pfizer-Allergan...more

5/18/2016 - Asset Stripping Corporate Taxes Debt Expanded Group Instruments (EGIs) Financial Instruments Internal Revenue Code (IRC) IRS Multinationals Proposed Regulation

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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