On January 18, 2022, Davis Polk partners Lucy Farr and Kara Mungovan will be among the speakers at the New York State Bar Association’s 2022 Annual Meeting. Lucy will speak on the “Section 163(n) Limitation on Disproportionate US Interest Expense – Theory and Some Practical Observations” panel. Topics discussed will include the real-world impact of the carryforward of disallowed interest expense and its interaction with section 163(j), the practical effect of using book (not tax) numbers to determine disproportionality, and the impact of losses on US interest expense deductibility.

Kara will speak on the “International Tax: A Globally Coordinated Minimum Tax Regime - How Close Are We Really?” panel. Topics discussed will include how aligned the OECD Pillar Two release will be with the current and future US GILTI and BEAT regimes, and what the potential policy and practical inconsistencies could be.

For more information, please visit the event website.