On May 5, 2023, Davis Polk partner Lucy Farr will be among the speakers at the American Bar Association Tax Section’s 2023 May tax meeting. Lucy will speak on the “What’s Wrong With Section 475?” panel. Topics discussed will include a series of issues and uncertainties that practitioners commonly confront when applying section 475, including the interaction of the dealer identification rules and the consolidated return rules, the ability of securities traders to elect mark-to-market for only a portion of their investment portfolio and the interplay between section 475 and other code sections, such as section 1256, section 1092, section 897 and section 988.