News & Analysis as of

Inflation Reduction Act (IRA) Excise Tax Tax Liability

Cadwalader, Wickersham & Taft LLP

Proposed Regulations for Buyback Tax Hit LBOs, Preferred Stock but Spare Tier 1 Capital

The government released proposed regulations this month implementing the excise tax imposed on repurchases of corporate stock that was enacted in 2022.  Although these regulations provide some welcome clarity as to the scope...more

Skadden, Arps, Slate, Meagher & Flom LLP

Newly Proposed Regulations on Stock Buyback Excise Tax Largely Adopt Approach From Initial IRS Guidance

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

Kohrman Jackson & Krantz LLP

Scrutiny on Personal Use of Business Jets Intensifies: IRS to Conduct Audits

Initially, tracking systems were employed to monitor the private jet usage of celebrities like Taylor Swift. Now, similar scrutiny will extend to executives who utilize business aircraft for personal purposes while claiming...more

Woodruff Sawyer

1% Excise Tax, SPACs, and Independent Director Personal Liability: The Rock and the Hard Place

Woodruff Sawyer on

Being stuck between the choice of either disappointing investors or facing potential personal liability is the very definition of being caught between a rock and a hard place. Tax liability insurance can take you to a more...more

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