Davis Polk partner William Curran will be among the speakers at PLI’s Consolidated Tax Return Regulations 2020 Program. Curran will be a speaker 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 on January 21-22, 2020, in New York.
For more information, please visit the event website.