Davis Polk partner William Curran will be among the speakers at PLI’s Consolidated Tax Return Regulations 2020 Program. Curran will be a speaker on the “Affiliation, Reverse Acquisitions and Accounting Issues” panel. Topics discussed will include:

  • The affiliation provisions of Section 1504 and the group continuation rules of Treas. Reg. Section 1.1502-75, including:
    • Review of the statutory requirements for affiliation
    • The application of the 80 percent voting power requirement
    • The decision in Alumax Inc. v. Comm’r.
    • The effect of bankruptcy proceedings on affiliation
    • The impact of the economic substance doctrine of Section 7701(o) on affiliation status
    • The application of Section 1504(a)(3) to a consolidated group and successor corporations.

 

The program will be held on January 21-22, 2020, in New York.

 

For more information, please visit the event website.

 

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