Davis Polk partners Rachel Kleinberg and David Schnabel and counsel Dana Trier will be among the speakers at PLI’s Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2018 conferences this Fall in New York, Chicago and Los Angeles.

Schnabel will speak on the “Planning for Private Equity and Hedge Fund Investments” panel at each program. This session will discuss planning for private equity and hedge fund investments, including investments in operating partnerships, debt pushdowns, rollover equity, planning under Sections 336(e) and 338, management compensation, and planning relating to various 2017 Tax Act provisions such as the new limitations on interest deductibility, the spread between the corporate tax rate and individual tax rate, the new carried interest rules, the new deduction under Section 199A, and the new expensing rules.

At the Chicago program, Trier will speak on the panel “Restructuring Multinational Groups After the 2017 Tax Act” panel. This panel with cover cross-border structuring issues and the impact of new GILTI, foreign-derived intangible income (“FDII”), base erosion anti-abuse tax (“BEAT”), Section 163(j) and anti-hybrid rules on the location of third-party and intercompany financing arrangements, tangible and intangible asset ownership, and intercompany service and contract arrangements. At the New York program, Trier will speak on the “Financial Instruments in M&A and Other Corporate Transactions” panel. This session will discuss structuring M&A financings and related transactions in a post-2017 Tax Act world, with a view to location and timing of deductions and income (including impacts of Section 163(j), BEAT and GILTI regimes).

At the Los Angeles program Kleinberg will speak on the “Current Issues in M&A” panel. This panel will discuss the effect of the 2017 Tax Act on M&A transactions. 

The programs will be held October 17-19, 2018 in New York, November 14-16, 2018 in Chicago and December 5-7, 2018 in Los Angeles.

For more information, please visit the event website.

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