Lauren Angelilli and Andrew Davis Speak at the American Bar Association’s 2024 Fall Tax Meeting

Cravath partners Lauren Angelilli and Andrew T. Davis participated in the American Bar Association’s 2024 Fall Tax Meeting, which was held virtually from September 23‑27, 2024.

Lauren spoke alongside officials from the Internal Revenue Service and Treasury Department on a panel entitled “Section 355 Delayed Distributions, Retentions, and Debt Exchanges,” which addressed critical issues regarding tax‑free spin‑offs under section 355, including the difference between delayed distributions of stock of a controlled corporation and retentions of stock in a controlled corporation, and a variety of issues related to section 355, including requirements that must be satisfied for a debt‑for‑debt exchange facilitated by an investment bank in connection with a spin-off to be respected as part of a tax‑free spin‑off under section 361.

Andrew spoke on a panel entitled “Affiliated & Consolidated Current Developments,” which focused on recent affiliated and consolidated return developments, including Notice 2024‑54’s announcement of forthcoming proposed consolidated return regulations with respect to partnership interests held by members of a consolidated group and recent non-precedential guidance in the context of beneficial stock ownership.