Michael Desmond will speak at the Practising Law Institute (PLI) conference "Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2025" on October 22, 2025. Desmond will co-present "Tax Controversy Issues in M&A Transactions." This session will consider how the evolution in IRS enforcement activity may impact transactional planning by examining recent litigated cases and administrative enforcement activities. After completing this session, participants will be able to:

• Identify issues on the front end of transactional planning that could come under audit scrutiny later
• Document and substantiate key facts and considerations in order to prepare a transaction for audit
• Understand where the IRS is deploying its enforcement resources
• Appreciate how courts evaluate transactional planning in litigated cases