On February 3, 2026, Davis Polk partner and Tax practice head David Schnabel and partner Bill Curran will be among the speakers at Practising Law Institute’s “Cross-Border M&A Tax Planning 2026: Is This What It Was Like Before Covid?” program.

David will co-chair the event, offer opening remarks and moderate the “Sales by U.S. Companies of Non-U.S. Businesses” panel. The discussion will focus on the issues that arise when a U.S. company sells a non-U.S. business. David will also moderate the “Global M&A – Survey of Market Activity and Trends” panel. Topics discussed will include 2025 deal activity and what is to come for the year ahead.

Bill will speak on the “Global Partnership Transactions” panel. Topics discussed will include potential traps and opportunities in connection with the formation and disposition of cross-border partnerships, including Section 721(c), Section 864(c)(8) and related withholding, and Section 1248, the scope of the proposed related party basis adjustment rules and the related disclosure that is now required, as well as the nuances of the UP-C structure for partnership IPOs and structuring considerations for future M&A transactions.

For more information, please visit the event website. 

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