New York
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+1 212 848 4106
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+1 646 848 4106
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Peter
H.
Blessing
Partner
Education
New York University School of Law, LL.M. in Taxation
Columbia University School of Law, J.D.
Princeton University, B.A.
Practice
Peter Blessing’s practice focuses on tax aspects of (i) mergers and acquisitions, spin-offs, restructurings, and joint ventures, (ii) investment funds and REITs, (iii) structured financings and capital markets, and (iv) tax controversies. He works regularly with both industrial and financial clients.
Experience
- Cross-border acquisitions and restructurings, public and private financings, and IP planning for a variety of multinationals
- Private equity and direct investments for sovereign wealth funds, etc., distressed debt planning, and fund offerings
- IRS controversies in respect of cross-border financings, FTCs, transfer pricing, etc.
- Legal opinion practice for FIN 48, etc.
Selected Professional & Business Activities
- Co-Chair, Taxes Committee of the International Bar Association; member, Executive Committee, New York State Bar Association Tax Section (Chair, 2010); member, Permanent Scientific Committee of the International Fiscal Association and Executive Committee member of IFA USA Branch; member, Steering Committee, Working Group on Legal Opinions; member, American Bar Association Tax Section (Committee on Foreign Activities of US Taxpayers (Chair, 2004-2006), Tax Court Committee, Committee on Government Submissions and liaison with WGLO); Board member, International Tax Institute, Inc. (President, 2003-2005); Adjunct Professor, Columbia Law School (JD program) (2008-11); Fellow, American College of Tax Counsel; member, Tax Forum; member, International Tax Group.
- Frequent lecturer on various aspects of taxation and cross-border taxation at seminars sponsored by IFA, IBA, ABA, ALI-ABA, NYSBA, CTF, NYU, PLI, GW-IRS, California State Bar, and others.
Publications
- Authored a treatise, Income Tax Treaties of the United States (Warren Gorham & Lamont), and two volumes in the BNA Tax Management Portfolio series: The Branch Profits Tax (co-author) and Source of Income.
- Numerous articles published in various professional journals. Recent pieces include, e.g., “Acquisition and Sale of Brazilian Companies by U.S. Companies” (co-author); “Privileged Communications in the Context of U.S. Taxation;” “Limitation on Benefits as Applicable to Commercial Entities under the Canada-US Income Tax Treaty;” “The Debt-Equity Connundrum: A Prequel;” “Divergence of Third Party Pricing from Arm’s Length Results;” “Domestic and Treaty Anti-Abuse Rules as Applied to Dividends;” and “Sovereign Immunity: A US and European View” (co-author).
Recognition by Clients and Peers
Best Lawyers of America 2012 (New York Area “Tax Lawyer of the Year”), Chambers USA (Tax, Tier 1), Chambers Global, Euromoney’s Best of the Best USA 2012 (top 30 tax lawyers), The Legal 500, International Tax Review (World Tax 2012), Tax Directors’ Handbook, Who’s Who of Corporate Tax Lawyers, PLC Which Lawyer?, Super Lawyers, etc.
Bar Admissions/Qualifications
New York
Courts
United States Tax Court
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