Results may vary depending on your particular facts and legal circumstances.
No aspect of this advertisement has been approved by the Supreme Court of New Jersey.
A description of the selection methodology can be found here.
Results may vary depending on your particular facts and legal circumstances.
No aspect of this advertisement has been approved by the Supreme Court of New Jersey.
A description of the selection methodology can be found here.
Member
Peter Connors is a distinguished tax professional concentrating his practice on cross-border transactions and tax controversy matters and has more than four decades of experience in related areas of tax law, including financial transactions, corporate reorganizations, renewable energy investments, controversy matters, and providing legal counsel and tax strategies for multinational clients.
A portion of Peter’s innovative practice is focused on the intersection of renewable energy and tax law, particularly involving carbon capture and sequestration (CCS) and hydrogen. He has experience serving as tax counsel and advising clients regarding the application of Internal Revenue Code Section 45Q tax credits for carbon capture, sequestration, and storage (CCUS). In this regard, he recently served as tax counsel to the project company in one of the largest carbon capture projects utilizing Section 45Q tax credits, receiving financing through a tax equity partnership.
Prior to joining the firm, Peter was a partner with an Am Law 100 firm serving technology, E&I funds, and financial institutions. He also served as a principal in the International Tax Services Group of Ernst & Young in New York.
Peter is a highly regarded practitioner in the tax industry, recently completing a four-year term as president of the International Fiscal Association’s (IFA) USA Branch. He is the only individual to serve as both president of the American College of Tax Counsel and the IFA USA Branch.
Peter is a prolific author on tax-related subjects, with more than 150 published articles in the field of taxation and over 500 citations in Tax Notes. He served as a co-author of a report on carbon capture for the United States Energy Association and Department of Energy entitled “Review of Federal, State, and Regional Tax Strategies and Opportunities for CO2-EOR-Storage and the CCUS Value Chain.” He is a member of the Bloomberg BNA Tax Advisory Board and has served as the Special Industries Editor for the Journal of Taxation since 2006.
Peter earned a J.D. from the University of Richmond School of Law and received an LL.M. in Tax from the New York University School of Law. He has been recognized in New York Super Lawyers for more than 15 years and has been listed in The Best Lawyers in America® in Tax Law since 2016. Peter has been reviewed by Chambers USA in the New York Tax section eight times. He has also been recognized as a leader in connection with the development of hydrogen as an alternative energy source by the American Energy Society.
Featured, “People On The Move: Peter J. Connors, Norris McLaughlin, P.A.” Crain’s New York Business, June 24, 2024.
Featured, “PEOPLE ON THE MOVE IN NEW YORK: Peter Connors,” New York Business Journal, June 12, 2024.
Published, “IRS Clarifies Corporate AMT Guidance With Additional Notices,” Bloomberg Tax Management Memorandum, January 9, 2024.
Published, “IRS Issues First Guidance on the Corporate Alternative Minimum Tax,” Bloomberg Tax Management Memorandum, February 17, 2023.
Published, “6 Tax Considerations For Life Sciences Collaboration Deals,” Law360, October 20, 2022.
Published, “Infrastructure Law Adds Important Crypto Provisions,” JDSupra, January 11, 2022.
Published, “The Hydrogen Provisions of the Bi-Partisan Infrastructure Plan,” Pratt’s Energy Law Report, October 2021.
Published, “IRS Ruling Opens Runway For Stalled Carbon Capture Deals,” Law360, July 9, 2021.
Published, “The Next Step: FinCEN Proposes to Require Reporting of Cryptocurrency Positions Held in Foreign Accounts,” On the Chain, February 16, 2021.
Published, “Financial Incentives for Carbon Capture, Use and Sequestration – The Updated Section 45Q Program,” PLI, January 18, 2021.
Published, “Report on Proposed and Final Regulations Addressing GILTI and Subpart F High Taxed Income Exception,” New Jersey State Bar Association, September 29, 2020.
Published, “Review of Federal, State, and Regional Tax Strategies and Opportunities for CO2 EOR Storage and the CCUS Value Chain,” September 21, 2020.
Published, “Report on the Proposed Foreign Tax Credit Regulations,” NYSBA, February 5, 2019.
“A Second Bite at the APA: Altera’s Rehearing and the Potential Invalidity of Cost Sharing Regulations—Part Three,” Bloomberg Tax Management International Journal, November 3, 2018.
Published, “A Second Bite at the APA: Altera’s Rehearing and the Potential Invalidity of Cost Sharing Regulations—Part Two,” Bloomberg Tax Management International Journal, November 1, 2018.
Published, “A Second Bite at the APA: Altera’s Rehearing and the Potential Invalidity of Cost Sharing Regulations—Part One,” Bloomberg Tax Management International Journal, October 31, 2018.
Published, “New York State Bar Association Tax Section Report on Section 894(c) and ECI,” NYSBA, June 13, 2017.
Published, “The ETE-Williams Dispute Through A Tax Lens,” Law 360, August 22, 2016.
Published, “Final Section 385 Regulations,” Bloomberg BNA Tax Management International Journal, February and March 2017.
Published, “Proposed Regulations Under §385 Classifying Interests in a Corporation,” Bloomberg BNA Tax Management International Journal, July 2016.
Published, “Inversions: Recent Developments and 2 Predictions,” Law 360, January 2016.
Published, “IRS Proposes to Revise the Treatment of Nonperiodic Payments,” Tax Notes Today, June 2015.
Published, “Inversions to the US: Going Against the Tide?,” Practical Law, March 2015.
Published, “IRS Announces Intent to Tax Transfers to Partnerships with Foreign Partners,” JDSupra, November 24, 2015.
Published, “Assessing Retroactive Inversion Legislation And Its Risks,” Law 360, September 2014.
Published, “Inbound Inversions for German Technology Companies,” Tax Management International Journal, December 2014.
Published, “The Legal and Practical Implications of Retroactive Legislation Targeting Inversions,” Harvard Law School Forum on Corporate Governance and Financial Regulation, September 16, 2014.
Published, “New York State Bar Association Tax Section Report on Proposed Regulations under Section 871(m),” NYSBA, May 20, 2014.
Published, “Updating the Sovereign Tax Exemption: The Proposed Regulations Under Section 892,” Tax Management International, April 2012.
Published, “General Tax Accounting Rules, IFRS and Derivatives,” Derivatives & Financial Instruments, April 2010.
Published, “NYSBA Report on Registered Debt Following the Hire Act,” (December 15, 2011) (with Welsh)
Published, “NYSBA Report on Issues Under Section 909 of the Code,” November 8, 2010.
Published, “General Tax Accounting Rules, IFRS and Derivatives,” Derivatives & Financial Instruments, April 2010.
Published, “NYSBA Report on Qualified Intermediary and Related Withholding and Information Reporting Legislation Proposed by the Administration,” September 10, 2009.
Published, U.S. Reporter, “Foreign Exchange Issues in International Taxation,” Cahiers, International Fiscal Association, 2009.
Published, “China Tax Treaty Preference: Burden of Proof & Documentation,” Practical Asian Tax Strategies, December 2008.
Published, “NYSBA Report on the Proposed Contract Manufacturing Regulations,” August 1, 2008.
Published, “PRC Taxes on Hong Kong & Foreign Companies: Clarifications, Changes, Challenges & Opportunities,” China Law & Practice, May 21, 2007.
Published, “New French Protocol Updates U.S.-France Income Tax Treaty,” Tax Management International, July 14, 2006.
Published, “Application of U.S. Treaties to Hybrid Entities,” Tax Management International, March 10, 2006.
Published, “IRS Releases Second Round of Advice on Repatriation Rules,” Corporate Finance, Fall 2005.
Published, “NatWest Decision Prevents IRS Adjustments of US Branch’s Interest Deductions: Impact on Capital Allocation,” Derivatives & Financial Instruments, July/August 2005.
Published, “Section 965 Update, with Michael A. Beckius, Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings, Oct, 2005.
Published, “The Financial Products Area – recent US developments,” The Euromoney Corporate Tax Handbook, 2006.
Published, “Covered BONDS – a global taxation perspective,” The Euromoney Corporate Tax Handbook, 2006.
Published, TM Portfolio 809-3d—The Branch Related Taxes of Section 884, January 2005.
Published, “Selected International Provisions of the American Jobs Creation Act of 2004 Affecting Canadians Doing Business in the U.S.,” Corporate Finance, Winter 2005.
Published, “Selected Global Tax Planning Issues” Euromoney Global Tax Handbook, 2005
Published, “Special Supplement on the International Provisions of the American Jobs Creation Act of 2004,” Tax Management, December 13, 2004.
Published, “Does Dow Chemical’s Victory in its COLI Case Signal the Demise of the Factual Sham Doctrine?,” The Journal of Taxation of Financial Products, Winter 2004.
Published, “IRS Issues Proposed Section 1446 Regulations Replacing Revenue Procedure 89-31,” The Real Estate Finance Journal, Fall 2004.
Published, “The Proposed Regulations on Foreign-Currency-Denominated Contingent Debt Instruments,” Tax Management, May 3, 2004.
Published, “Recent Cases Involving the Economic Sham Transaction Doctrine – Or Whatever They are Calling it Now,” PLI, July 2004.
Published, “IRS Rules that Interest in Felines PRIDES Structure is Deductible,” Corporate Finance, Winter 2004.
Published, “IRS Withdraws the Check-the-Box Regulations’ Extraordinary Transaction Rule,” Corporate Finance, Winter 2004.
Published, “New United States—United Kingdom Income Tax Treaty,” International Bureau of Fiscal Discrimination, Derivatives & Financial Instruments, November/December 2003.
Published, “The New Tax Shelter Landscape,” Treasury & Taxation, January 14, 2002.
Published, “Carryover of Corporate Attributes in International Reorganizations,” Journal of Corporate Taxation, Winter 2002.
Published, “2000 Tax Act Changes to Derivatives Taxation,” Derivatives & Financial Instruments Journal, 2001.
Published, “FAS 133 Raises Complex Issues for Corporate Treasurers,” FAS 133 Supplement, Institutional Investor, November 2001.
Published, “IRS Issues Reverse Hybrid Regulations,” Derivatives & Financial Instruments Journal, November 2001.
Published, “Hybrid Instruments – Current Issues,” Tax Strategies for Corporate Published, Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations, and Restructurings, October 2001.
Published, “The Extraterritorial Income Exclusion Regime Increases Scope of Export Incentives,” International Tax Review, August 2001.
Published, “IES Industries Revisited,” Tax Management Memorandum, August 2001.
Published, “Final Regulation Governing Pre-Reorganization Redemptions and Distributions Issued,” Corporate Finance, July 2001.
Published, “IRS Releases Interest Capitalization Regulations,” Corporate Finance (July 2001).
Published, “IRS Releases Regulations Covering Financial Product Issues,” International Tax Planning Review, May 2001.
Published, “A Practical Guide for the New QI,” Journal of International Taxation, April 2001.
Published, “Elections Create Opportunities for Foreign Currency Transactions,” Journal of Taxation of Financial Institutions, February 2001.
Published, “Final FSC Replacement Legislation,” Corporate Tax and Business Planning Review, February 2001.
Published, “Nine Months of Working with the QI Agreement,” Journal of International Taxation, November 2000.
Published, “IRS Releases Final Qualified Intermediary Agreement,” Derivatives & Financial Instruments, November 2000.
Published, “IRS Continues Attack on Corporate Tax Shelters,” Corporate Finance, November 2000.
Published, “Hybrid Instruments – Current Issues,” Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations, and Restructurings, October 2000.
Published, “The Mark-to-Market Rules of Section 475,” Tax Management Portfolio, Bureau of National Affairs, June 2000.
Published, “New Tax Act Requires Taxpayers to Modify Hedging Programs,” Derivatives & Financial Instruments, March/April 2000.
Published, “Financing International Operations,” New England Regional Meeting, International Fiscal Association, November 1999.
Published, “Hybrid Instruments – Current Issues,” Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations, and Restructurings, October 1999.
Published, “New Regulations on the Euro’s Impact Liberally Defer the Taxable Event,” Journal of Bank Taxation, Winter 1999.
Published, “Recent Developments Affecting Securities Dealers and Traders Under Section 475,” Tax Management Memorandum, October 1998.
Published, “Hybrid Instruments – Current Issues,” Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations, and Restructurings, October 1998.
Published, “Recent Developments Affecting Code Section 475,” Tax Management Memorandum – Corporate Tax and Business Planning Review, April 1998.
Published, “Debt-Equity Conversions,” Journal of Bank Taxation, Fall 1997.
Published, “Substantiation for Foreign Tax Credits,” Journal of Bank Taxation, Fall 1997.
Published, “Hybrid Instruments – Current Issues,” Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations, and Restructurings, October 1997.
Published, “IRS Rules that Letter of Credit Fees are Sourced Under Interest-Sourcing Rules,” Journal of Bank Taxation, Spring 1997.
Published, “Nova Scotia ULCs Can Check-the-Box,” Corporate Finance, 1997.
Published, “New Regulations Impact Notional Principal Contract Assignments,” BNA Financial Products Reporter, September 1996.
Published, “Foreign Broker Was Engaged in U.S. Trade or Business Through the Activities of an Agent: InverWorld, Inc. v. Cm’r.,” Tax Management Int’l, 1996.
Published, “Final Transfer-Pricing Penalty Regulations Seek Compliance with Arm’s-Length Standard,” Journal of Bank Taxation, Fall 1996.
Published, “Final Regulations Narrow Favorable Presumptions and Expand Scope of Anti-Conduit Financing Rules,” Journal of Bank Taxation, Spring 1996.
Published, “Final Consolidated Group Hedging Regulations Permit Retroactive Elections,” Journal of Taxation, April 1996.
Published, “Proposed U.S. Regulations Curb Transactions Involving Cross-Border Leases,” Corporate Finance, 1996.
Published, “Proposed Regulations Define Active Banks and Securities Firms for PFIC Purposes,” Journal of Bank Taxation, Fall 1995.
Published, “Consolidated Hedging Prop. Regs. Begin to Provide Workable Rules,” Journal of Taxation, July 1995.
Published, “Despite Narrow Drafting, Anti-Conduit Proposed Regulations Raise Serious Issues for Banks,” Journal of Bank Taxation, Spring 1995.
Published, “Final Business Hedging Regulations Are a Big Improvement, but Hard Questions Are Left Unresolved,” Journal of Taxation, January 1995.
Published, “Amendments to U.S.-Canada Treaty Make Withholding and Other Income Tax Changes,” Journal of Bank Taxation, Winter 1995.
Published, “Taxation of Hedging Transactions,” Chapter 16, Controlling and Managing Derivatives Risks: A Handbook for Corporate Directors, Treasurers and Institutional Investors, Irwin Financial Press, 1995.
Published, “U.S. Proposes Contingent Debt Regulations,” Corporate Finance, 1995.
Published, “IRS Rules on Interest Methods and Withholding on Swaps; Tax Court Restricts Subpart F,” Journal of Bank Taxation, Fall 1994.
Published, “IRS Clarifies OID Rules for Variable Rate Debt and Accounting Method Changes,” Journal of Taxation, July 1994.
Published, “Opportunities for CFCs to Defer Income Restricted under RRA `93,” Journal of Bank Taxation, Spring 1994.
Published, “Cross-Border Asset Secuntizations: Issues and Opportunities for Canadian Corporations,” Corporate Finance, 1994.
Published, “New Transfer Pricing Penalty Regulations Require Immediate Action” Corporate Finance, 1994.
Published, “IRS Issues Final Rules Relating to the Taxation of Business Hedging Transactions,” Corporate Finance, 1994.
Published, “Proposed Regulations Regarding Accounting for Notional Principal Contracts,” American Bar Association, Section of Taxation, Committee on Sales and Financial Transactions, 1993.
Published, “Comments Concerning Proposed Regulations under Sections 1221 and 446 (Taxation of Gains from Hedging Transactions),” American Bar Association, Section of Taxation, Committee on Sales and Financial Transactions, 1993.
Published, “Final Regulations Affect Timing of Deductions for Amounts Owed to Related Foreign Persons,” Journal of Bank Taxation, Fall 1993.
Published, “Dual Consolidated Loss Rules Eased in Final Regulations,” Journal of Bank Taxation, Spring 1993.
Published, “Treatment of Notional Principal Contracts Further Complicated by Prop. Regs.,” Journal of Taxation, March 1992.
Published, “Advance Pricing Agreements can Prevent Double Tax of Global Trading Profits,” Journal of Bank Taxation, Fall 1992.
Published, “Report on the Proposed Cross-Border Securities Lending Regulations,” American Bar Association, Section of Taxation, Committee on Sales and Financial Transactions, April 1992.
Published, “U.S. Rulings Protect International Banking Income for Double Taxation” Corporate Finance, 1992.
Published, “Strategies for Leveraging Canadian Subsidiaries,” Corporate Finance, 1992.
Published, “New United States-Netherlands Treaty Will Affect Canadian Multinational Financing Arrangements,” Corporate Finance, 1992.
Published, “Hedging Profits or Losses – A Move in the U.S. to Full Income Treatment,” Corporate Finance, 1992.
Published, “New Interest Expense Allocation Rules Pose Practical Difficulties for Foreign Banks,” with Blanco and Epstein, Journal of Taxation, 1992.
Published, “Final and Proposed Regulations Expand Available Foreign Currency Hedging Opportunities,” with Weinrib and Driscoll, Journal of Taxation, August 1992.
Published, “Treatment of Notional Principal Contracts Further Complicated by Prop. Regs.,” Journal of Taxation, March 1992.
Published, “Planning Opportunities Under the Proposed Earnings-Stripping Regulations,” with Kroop, Journal of Bank Taxation, Fall 1991.
Published, “Contingent Debt Instruments Are Divided and Conquered under the New OID Proposed Regulations,” Journal of Taxation, July 1991.
Published, “Application of Market Discount Rules to Speculative Bonds,” American Bar Association, Section of Taxation, Committee on Sales and Financial Transactions, May 1991.
Published, “Final Regulations Ease Rules for Portfolio Bearer Debt Offerings,” Journal of Taxation, September 1990.
Published, “Report on Sections 243 and 453, as Amended by the Omnibus Budget Reconciliation Act (OBRA),” American Bar Association, Section of Taxation, Committee on Sales and Financial Transactions, 1988.
Published, “Comments on the Implications of Arkansas Best on the Section 1256(e) Hedging Exception,” American Bar Association, Section of Taxation, Committee on Sales and Financial Transactions, 1988.
Published, “Comments on the Treatment of Interest Rate Swap Payments,” American Bar Association, Section of Taxation, Committee on Sales and Financial Transactions, 1988.
Published, “Recent IRS Ruling Focuses on LDC Debt Transactions,” International Tax Journal, 1988.
Published, “New Mixed Straddle Regulations Answer Many Questions But Issues Remain Unresolved,” Journal of Taxation, December 1985.
Published, “Important Developments, U.S. Activities of Foreigners and Tax Treaties,” Tax Lawyer, 1985.
Published, “Important Developments, U.S. Activities of Foreigners and Tax Treaties,” Tax Lawyer, 1984.
Published, “New Foreign Tax Credit Rules Create Separate Return Limitation,” Journal of Taxation (Shop Talk), October 1984.
Published, “Important Developments, U.S. Activities of Foreigners and Tax Treaties,” Tax Lawyer, 1983.
Published, “The New Provisions Concerning the Reporting of International Transactions: An Analysis of TEFRA, the Tax Haven Report and New Form 5471,” Journal of Taxation, July 1983.
Published, “Acquisitions and the New Tax Law,” Corporate Director, October 1982.
Published, “Aliens May File Fiscal-Year Returns:” What are the Implications of the Service’s New Position?,” Journal of Taxation, November 1981.
Published, “What You Should Know About Blocked Foreign Income,” Prentice-Hall, US Taxation of International Operations, August 1981.
Published, U.S. Eases Foreigners’ Right to Elect Fiscal Tax Year,” International Tax Report, June 1981.
Published, “IRS Puts Tough Limits on Election of Fiscal Year by Foreign Individuals,” Journal of Taxation, September 1980.
Published, “Bankruptcy Reform: Relief for Individuals with Regular Income,” University of Richmond Law Review, 1979.
Presenter, Best Practices in Tax & Treasury , Presentation, October 2001.
