Davis Polk Tax practice head David Schnabel and partners Corey Goodman and Ethan Goldman will be among the speakers at the Practising Law Institute’s “Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2022” programs.

The program will be held in Chicago on April 26-28, 2022, in New York on May 9-11, 2022 and in San Francisco on June 7-9, 2022.

David will speak on the “New Partnership Audit Rules” panel at each of the programs. Topics discussed will include the rules governing partnership tax audits introduced by the Bipartisan Budget Act of 2015, the many issues they raise and what needs to be done now in drafting partnership agreements and disclosure document.

David will also speak on the “Private Equity” panel at each of the programs. Topics discussed will include the basics of private equity structures, topside planning to accommodate the tax objectives of fund managers and investors, including issues raised in cross-border investing, such as UBTI, ECI, FIRPTA, sovereign investors (Section 892), with discussion of recent changes to the Code and transaction and exit planning.

Ethan will speak on the “Compensatory Interests and Other Arrangements panel at the Chicago program. Topics discussed will include the use of partnership equity for compensation, such as profit interests and regular, or “capital,” interests, as well as compensatory payments in the partnership context, the impact of the 2017 Tax Act on those arrangements and self-employment tax and partner/employee issues.

Corey will speak on the “Distressed Partnerships (Including Bankruptcy and CARES Act)” panel at the New York program. Topics discussed will include an overview of common forms of debt workouts and restructuring transactions (e.g., bankruptcy, foreclosure, debt modification, contribution of debt to equity), which will likely see a resurgence in the wake of the COVID-19 pandemic and the tax implications that follow when those transactions are carried out through partnerships.

For more information, please visit the event website.

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