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Interim Guidance on Stock Buyback Excise Tax Confirms Broad ...


IRS - Proskauer Tax Talks

On December 27, 2022, the Internal Revenue Service (“IRS”) and the U.S. Department of the Treasury (the “Treasury”) released Notice 2023-2 (the “Notice”), which ...

Corporate Stock Repurchase Excise Tax: Proposed Regulations ...

On December 27, 2022, the U.S. Treasury Department (Treasury) and Internal Revenue Service (IRS) issued interim guidance in ... The proposed regulations confirm ...

NYSBA Continues Push for Changes to Corporate Stock Buyback Tax

Under the Statutory Foreign Buyback Rule, the Excise Tax applies where funds leave the corporate solution of a domestic corporation to acquire ...

Monthly Tax Roundup (Volume 2, Issue 2) - Miller & Chevalier

When issuing Notice 2023-2, Treasury and the IRS were concerned that taxpayers could avoid the "hook stock" rule in section 4501(d) by funding a ...

Understanding Stock Buybacks — Should We Tax Them?

We note that equalizing the tax treatment of buybacks and dividends by imposing an excise tax on buybacks would increase the effective marginal ...

Treasury and IRS publish proposed regulations concerning stock ...

SPACs. Treasury and the IRS confirmed their view that no specific rules relating to SPACs are necessary. Accordingly, repurchases of SPAC stock ...

Limit Stock Buyback Tax's Rules, Groups Tell IRS - Law360

A set of rules designed to prevent U.S. companies with foreign affiliates from circumventing the new excise tax on stock repurchases should ...

Corporate tax - Proskauer Tax Talks

The Treasury and the IRS took a literal interpretation of the statute; thus, the Tax applies broadly to stock repurchases and other transactions that are not ...

IRS Releases Interim Guidance on Stock Buyback Excise Tax

However, while this list is on its face extremely broad and applies regardless of whether there is any cash in these otherwise tax-free transactions, the Notice ...

Recent Tax Developments and Guidance - Hunton Andrews Kurth LLP

On December 27, 2022, the IRS and Treasury issued Notice 2023-02 (the “Excise Tax Notice”) to provide taxpayers with interim guidance regarding ...

The 1% Excise Tax on Stock Repurchases (Buybacks)

The 1% Excise Tax on Stock Repurchases (Buybacks) ... FY2031 period. President Biden and several Senators have proposed to increase the rate to 4% ...

US Tax - PwC Suite

US Treasury released proposed regulations on 12 April regarding the application of the excise tax on certain repurchases of corporate stock. Read more...

Excise Tax on Corporate Stock Repurchases Under the Inflation ...

The Internal Revenue Service (the “IRS”) published interim guidance ... However, the Notice confirms the broad scope of Section 4501, potentially ...

Debevoise Discusses Treasury Guidance on Corporate Minimum ...

The Notice clarifies that the Buyback Tax applies not only to a repurchase of publicly traded common stock, but also to a redemption of a public ...

Treasury Releases Proposed Regulations on 1% Tax on Stock ...

... rules governing the non-deductible 1% excise tax on corporate stock buybacks by publicly traded companies. The Proposed Regulations include ...

Proposed Regulations on Stock Repurchase Excise Tax - BDO USA

The Treasury Department and the IRS on April 9 released two sets of proposed regulations containing guidance on the application and reporting of the corporate ...

Banks and the Newly-Enacted Stock Buyback Tax - Vorys

Included within the Inflation Reduction Act of 2022 (the Act) signed into law by President Biden on August 16, 2022, is a one percent excise ...

Proposed regulations under the stock repurchase excise tax - Key ...

Treasury issued Notice 2023-2 on 27 December 2022, which provided interim guidance with respect to the stock repurchase excise tax. The ...

The 1% Excise Tax on Stock Repurchases (Buybacks) - Every CRS ...

client-update/irs-issues-interim-guidance-stock-repurchase-excise-tax. Page 13. The 1% Excise Tax on Stock Repurchases (Buybacks). Congressional Research ...

Articles by Todd Gluth's Profile | JD Supra, Lexology, Mondaq ...

Interim Guidance on Stock Buyback Excise Tax Confirms Broad Application to M&A and Capital Market Transactions | JD Supra · a year ago |. By Stephanie Gentile ...