On February 12, 2025, Davis Polk partner and Tax practice head David Schnabel and partner Bill Curran will be among the speakers at Practising Law Institute’s “Cross-Border M&A Tax Planning 2025: It’s Not Getting Any Easier” program.

David will give opening remarks and moderate the “Sales by U.S. Companies of Non-U.S. Businesses” panel. Topics discussed will include how to structure a sale in the most tax-efficient manner, applying the Section 245A dividends received deduction rules (“DRD”) when selling a non-U.S. subsidiary, the potential benefits and burdens of making a Section 228(g) election, and more.

Additionally, David will moderate the “Global M&A – Survey of Market Activity and Trends” panels. Topics discussed will include deal trends in disposition activity, financing challenges and debt term trends, and public alternatives.

Bill will speak on the “UP-Cs and Global Partnership Transactions” panel. Topics discussed will include the how to organize and sell global partnerships and joint ventures, the nuances of the UP-C structure for partnership IPOs, such as tax receivable agreements, PTP considerations and structuring considerations for future M&A transactions, and how to recognize potential traps and opportunities in connection with the formation and disposition of cross-border partnerships. 

For more information, please visit the event website. 

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