Peter Connors

Peter Connors

Orrick, Herrington & Sutcliffe LLP

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IRS Reverses its Position Regarding the Treatment of Merger Breakup Fees

In July 2014 AbbVie Inc. and Shire Plc's announced a $54.8 billion merger deal that would have made AbbVie the largest U.S. company to move its legal residence, though not its operations, abroad in order to lower its tax rate...more

3/3/2017 - AbbVie Capital Losses Inversion IRS Offshore Companies Pharmaceutical Industry Shareholder Votes Stocks Tax Liability Tax Planning Tax Rates Termination Payments

IRS Releases New Regulations Regarding Dividend Equivalents

On January 19, 2017, the Internal Revenue Service (the “IRS”) issued final, temporary, and proposed regulations (the “Regulations”) under section 871(m) of the Internal Revenue Code of 1986, as amended (the “Code”). Code...more

2/2/2017 - Consumer Financial Products Derivatives Dividend-Equivalent Transactions Exchange-Traded Products Financial Markets Financial Sector Internal Revenue Code (IRC) IRS Master Limited Partnerships Partnerships Qualified Derivatives Dealers (QDDs) Section 871(m) Securities SIFMA Stocks

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

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

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