Davis Polk partner and Tax practice head David Schnabel and partners Bill Curran, Lucy Farr, Corey Goodman and Kara Mungovan will be among the speakers at the Practising Law Institute’s “Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2025.”

The program will be held in New York on October 22-24, 2025, in Chicago on November 12-14, 2025, and in Los Angeles on December 10-12, 2025.

David will speak on the “Private Equity: Buying and Selling Partnerships” panel at the New York program. Topics discussed will include structure rollovers, redemptions and leveraged distributions, common issues to consider when evaluating a tax receivable agreement and the structural framework of exit transactions, including UP-C exits.

Bill will speak on the “Restructuring Multinational Groups” panel at the Chicago program and Corey will speak at the Los Angeles program. Topics discussed will include cross-border structuring issues and the impact of the global intangible low-taxed income, foreign-derived intangible income, base erosion anti-abuse tax, Section 163(j) and anti-hybrid rules, as well as pending legislative and international proposals, the location of third-party and intercompany financing arrangements, tangible and intangible asset ownership, and intercompany service and contract arrangements. 

Lucy will speak on the “Current Issues in Debt Structuring (and Restructuring)” panel at the Los Angeles program. Topics discussed will include the competing tax characterizations of partial debt cancellation transactions, the types of deal term changes that can impact a characterization change and the ways cancellation of debt (COD) income interacts with the limitation on business interest expense of Section 163(j).

Kara will speak on the “Current Issues in Divisive Strategies” panel at the New York program. Topics discussed will include the requirements for a tax-free transaction under Section 355, the effects of recent guidance impacting divisive transactions and the considerations that weigh for and against seeking a private letter ruling.

For more information, please visit the event website. 

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