Tax Expertise

Peter maintains a broad tax practice, with an emphasis on partnership, S corporation, and international taxation. He regularly serves as outside tax counsel to other law firms on M&A and other business transactions. Recent engagements include:

• Lead tax counsel on M&A transactions involving construction, oilfield services, and consumer products businesses.

• Draft and review partnership allocation and distribution provisions, including for partnership profits interests.

• Develop a strategy for the tax-efficient restructuring a troubled partnership.

• Advise on the tax consequences of complex like-kind exchanges, condemnation proceedings, and other real estate transactions.

• Restructure a foreign holding company in response to tax legislation.

• Advise international clients on the income and estate tax consequences of investment in the United States.

• Help clients resolve foreign reporting issues, including through the OVDP and Streamlined programs.

• Successfully resolved contested tax issues in examinations, IRS appeals and in US Tax Court on issues including theft losses, inventory taxation, financial products and hobby losses.

• Assist several nonprofits in obtaining tax exempt status.