On December 9 and 10, 2026, Davis Polk partners Lucy Farr and Corey Goodman will be among the speakers at PLI’s “Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2026” program. 

Corey will speak on the “Restructuring multinational groups” panel. Topics discussed will include foreign entities and financing structures that facilitate repatriation and use of tax attributes; international tax provisions, such as NCTI, FDDEI, BEAT, and 163(j), to compute U.S. taxable income; and the impact of new legislation, regulations, and other guidance on group restructurings and other internal transactions.

Lucy will speak on the “Current issues in debt structuring (and restructuring)” panel. Topics discussed will include the competing tax characterizations of partial debt cancellation transactions, 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).

For more information, please visit the event website.

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