George Hani and Chadwick Roland will speak at the Practising Law Institute's Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2025 conference on November 12-13, 2025.

Hani 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 recently 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

Rowland will present, as a part of a panel, "Understanding and Managing Stock Basis and Earnings and Profits (E&P)." This panel will review the evolving law related to stock basis and E&P of U.S. and foreign corporations in light of significant changes made by the 2017 Tax Act and the Inflation Reduction Act of 2022 (IRA) and discuss potential further tax reform. After completing this session, participants will be able to:

• Calculate the value of stock basis and E&P in a post-IRA, post-2017 Tax Act world
• Employ planning techniques for optimizing attributes and avoiding pitfalls in business transactions
• Assess the impact of the corporate alternative minimum tax (CAMT) on stock basis and E&P determinations