Davis Polk partners Mary Conway, Lucy Farr, and Rachel Kleinberg will be among the speakers at the American Bar Association's 2018 Fall Tax Meeting .
Conway will moderate the "Cryptocurrency Funds" panel. Topics will include the treatment of virtual currencies for purposes of sections 721, the application of the straddle rules and the wash sale rules, the section 475(f) election, reverse section 704(c) allocations, section 864(b) and the FATCA rules, as well as choice-of-entity considerations for virtual currency funds.
Farr will moderate the “Banks and the BEAT" panel. This session will discuss the questions confronting financial institutions as they navigate the BEAT, including the scope of the "qualified derivative" exemption, the impact of derivatives on the base erosions percentages, the effect of the global dealing rules and the special issues facing U.S. branches of foreign banks.
Kleinberg will speak on the "Current Developments in Corporate Tax" panel. This panel will discuss a number of interesting PLRs and notices from the IRS dealing with section 355 transactions, including PLRs presenting issues under the business purpose requirement and the device prohibition, rulings issued under the new Transactional Ruling program (Rev. Proc. 2017-52), recent Treasury and IRS pronouncements regarding the no net value regulations, and the recently issued May Company regulations, and issues involving the interplay of new section 163(j) and section 382.
The program will be held October 4-6, 2018, in Atlanta.
For more information, please visit the event website.