Davis Polk partner Kathleen Ferrell will be among the speakers at PLI’s Consolidated Tax Return Regulations 2018 program. Ferrell will speak on the “Affiliation, Reverse Acquisitions and Accounting Issues” panel. Topics discussed will include:
- The affiliation provisions of Section 1504 and the group continuation rules of Treas. Reg. Section 1.1502-75, including:
- Review of the statutory requirements for affiliation
- The application of the 80 percent voting power requirement
- The decision in Alumax Inc. v. Comm'r.
- The effect of bankruptcy proceedings on affiliation
- The impact of the economic substance doctrine of Section 7701(o) on affiliation status;
- The application of Section 1504(a)(3) to a consolidated group and successor corporations
The program will be held February 20-21, 2018, in New York.
For more information, please visit the event website.