Davis Polk partner David Schnabel and counsel Dana Trier will be among the speakers at PLI's Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2019 programs this fall in New York, Chicago and Los Angeles. Schnabel will be a speaker on the "Planning for Private Equity and Hedge Fund Investments" panels. Trier will be a speaker on the "Restructuring Multinational Groups after the 2017 Tax Act" and “Financial Instruments in M&A and Other Corporate Transactions” panels.
The “Planning for Private Equity and Hedge Fund Investments” panel will discuss investments in operating partnerships, debt pushdowns, rollover equity, planning under Sections 336(e) and 338, management compensation, and planning relating to various 2017 Tax Act provisions such as the new limitations on interest deductibility, the spread between the corporate tax rate and individual tax rate, the new carried interest rules, the new deduction under Section 199A, and the new expensing rules.
The “Restructuring Multinational Groups after the 2017 Tax Act” panel will discuss cross-border structuring issues and the impact of new GILTI, foreign-derived intangible income ("FDII"), base erosion anti-abuse tax ("BEAT"), Section 163(j) and anti-hybrid rules on the location of third party and intercompany financing arrangements, tangible and intangible asset ownership, and intercompany service and contract arrangements.
The “Financial Instruments in M&A and Other Corporate Transactions” panel will discuss structuring M&A financings and related transactions in a post-2017 Tax Act world, including impacts of Section 163(j), BEAT and GILTI regimes.
The programs will be held October 16-18, 2019, in New York, November 13-15, 2019, in Chicago and December 4-6, 2019, in Los Angeles.
For more information, please visit the event website.