On April 12, 2024, the Treasury Department (Treasury) and Internal Revenue Service (IRS) issued proposed regulations (89 FR 25980 and 89 FR 25829) on the excise tax on stock buybacks enacted as part of the Inflation Reduction...more
4/18/2024
/ Acquisitions ,
Capital Markets ,
Corporate Governance ,
Excise Tax ,
Inflation Reduction Act (IRA) ,
International Tax Issues ,
IRS ,
Mergers ,
Private Equity ,
Proposed Regulation ,
Publicly-Traded Companies ,
Regulatory Agenda ,
Share Buybacks ,
Stock Repurchases ,
Tax Liability ,
U.S. Treasury
On January 2, 2024, the Internal Revenue Service (IRS) released two revenue procedures updating the IRS guidelines for private letter ruling (PLR) requests, Revenue Procedure 2024-1 and Revenue Procedure 2024-3 (the 2024...more
On July 26, 2023, the Internal Revenue Service (IRS) Chief Counsel’s Office announced that it would make permanent its pilot program of issuing “fast-track” private letter rulings for requests solely or primarily under the...more
On July 15, 2016, the Internal Revenue Service (IRS) released a new revenue procedure, Rev. Proc. 2016-40, providing safe harbors for transactions in which a corporation (Distributing) obtains the requisite control of a...more
7/26/2016
/ Acquisitions ,
Board of Directors ,
Capital Structures ,
Controlled Transactions ,
IRS ,
Recapitalization ,
Safe Harbors ,
Shareholder Distributions ,
Stocks ,
Subsidiaries ,
Tax-Free Spin-Offs
On July 14, 2016, the Internal Revenue Service (IRS) and Treasury Department proposed new Treasury regulations that, if finalized, would generally become effective for distributions under Section 355 of the Internal Revenue...more
On April 4, 2016, the Internal Revenue Service (IRS) and Treasury Department proposed new Treasury regulations that, if finalized, would become retroactively effective to April 4, 2016, and dramatically alter the tax...more