Mike Schler Speaks at PLI’s 2021 “Cross‑Border M&A Tax Planning” Program

On March 16, 2021, Cravath of counsel Michael L. Schler participated in “Cross‑Border M&A Tax Planning 2021: Doing Worldwide Deals from the Dining Room,” a program presented virtually by the Practising Law Institute. Mike spoke on a panel entitled “Sales by U.S. Companies of Non‑U.S. Businesses,” which discussed the application of the Section 245A dividends received deduction when selling a non‑U.S. subsidiary, potential benefits and disadvantages of making a Section 338(g) election, selling at various levels within a tiered structure, and the impact of earnings and profits of foreign corporations on sales.