On May 9 – 10, 2025, Davis Polk partners Lucy Farr and Kara Mungovan will be among the speakers at American Bar Association Tax Section’s 2025 May Tax Meeting.

Lucy will speak on the “Federal Income Tax Considerations for Investors and Traders in State Carbon Credits, Foreign Currency and Other Non-Securities, Non-Digital Property” panel. Topics discussed will include the classification of these assets for federal income tax purposes, the applicability of IRC sections 475(f) and section 1256, and the complex interplay between sections 475(f) and 988 in the context of foreign currency transactions.

Kara will speak on the “Section 304 Transactions” panel, which will explore how to determine whether section 304 applies in M&A transactions, the overlap between section 304 and section 351, basis recovery and earnings and profits (E&P) determinations in section 304 transactions, considerations for when an issuing corporation joins or leaves a consolidated group, partnerships and section 304 and cross-border aspects of section 304.

For more information, please visit the event website. 

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