Davis Polk partners Lucy Farr and Kathleen Ferrell and counsel Craig Phillips will be among the speakers at the 2015 Joint Fall CLE Meeting of the ABA Section of Taxation and Section of Real Property, Trust & Estate Law. The program will be held September 17-19, 2015, in Chicago.
Farr will moderate “Current Developments and Issues,” which will focus on current developments and practice issues in financial transactions and products, including the regulations under section 871(m), if released.
Ferrell will speak on the “Section 361(c) and Its Discontents” panel, which will describe section 361(c)’s role in the public spin-off context during the first decade-plus of the present millennium, and how its role has been impacted by the IRS’s no-rule position in Rev. Proc. 2013-3. Panelists will also explore several possible futures for the rule by considering regulatory guidance that the IRS and Treasury might issue interpreting the term “creditor.”
Phillips will participate in a two-part panel on “Issues Arising Under Section 956.” Panelists will review issues and risks arising under section 956, including a discussion of recent and anticipated guidance, and the interaction of section 956 with the partnership tax rules of Subchapter K.
For more information, please visit the event website.