On March 16, 2021, Davis Polk Tax Department head David Schnabel will chair Practising Law Institute's Cross-Border M&A Tax Planning 2021: Doing Worldwide Deals from the Dining Room webcast event. Schnabel will speak during the opening remarks and will moderate the "Global M&A – Survey of Market Activity and Trends" panel. Topics discussed will include:

  • Review of 2020 deal activity and expectations for 2021
  • Trends in disposition activity – spin-offs, carve-outs and sale
  • Financing challenges, debt terms, and unwind structures
  • Going public alternatives

Schnabel will also moderate the "Sales by U.S. Companies of Non-U.S. Businesses" panel. Topics discussed will include:

  • Application of the Section 245A DRD rules when selling a non-U.S. subsidiary
  • Potential benefits and burdens of making a Section 338(g) election
  • Selling at various levels within a tiered structure
  • Impact of E&P and PTEP

For more information, please visit the webcast website.