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Tax Reform Excise Tax Internal Revenue Service

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

McDermott Will & Emery

Weekly IRS Roundup April 8 – April 12, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 8, 2024 – April 12, 2024. April 8, 2024: The IRS released Internal Revenue Bulletin 2024-15,...more

McDermott Will & Emery

Weekly IRS Roundup May 30 – June 2, 2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 30, 2023 – June 2, 2023....more

McDermott Will & Emery

Weekly IRS Roundup April 17 – April 21, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 17, 2023 – April 21, 2023...more

A&O Shearman

Funding Rule Under Notice 2023-2 Expands the Scope of the Stock Buyback Excise Tax to Repurchases of Stock of Many Foreign...

A&O Shearman on

Notice 2023-2 (the “Notice”) provides guidance regarding the scope and application of the excise tax on buybacks of stock of publicly traded domestic corporations and certain publicly traded foreign corporations (the “Excise...more

McDermott Will & Emery

Weekly IRS Roundup January 17 – January 20, 2023

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 17, 2023 – January 20, 2023...more

Akerman LLP

President Biden Signs the Inflation Reduction Act into Law

Akerman LLP on

On August 16, 2022, President Joe Biden signed the Inflation Reduction Act of 2022 (H.R. 5376) (the IRA) into law. The key provisions that may affect the private equity sector and corporations include...more

Mayer Brown Free Writings + Perspectives

US Inflation Reduction Act – Corporate Minimum Tax and Stock Repurchase Excise Tax

If you thought the recent price increase at your neighborhood store was inflation’s last flop, think again. The Inflation Reduction Act (“IRA”), which was signed into law by President Biden on August 16, 2022, is estimated to...more

Pillsbury Winthrop Shaw Pittman LLP

Inflation Reduction Act of 2022 Includes New Corporate Tax Provisions

The new law generally imposes a 15% alternative minimum tax on book income of corporations with book income in excess of $1 billion. Public companies will generally be subject to a 1% excise tax on stock buybacks. ...more

ArentFox Schiff

Key Tax Changes Impacting Businesses in the New Inflation Reduction Act

ArentFox Schiff on

Today, President Joe Biden signed into law the Inflation Reduction Act of 2022 (the “Act”). Although the proposal further restricting the availability of long-term capital gain treatment with respect to carried interests...more

Polsinelli

The Proposed Inflation Reduction Act Moves to the House After the Senate Passes a Revised Version of the Bill

Polsinelli on

On August 7, 2022, the Senate passed the Inflation Reduction Act of 2022 (H.R. 5376) (the “Act”).  The announced goal of the Act is to create an economic initiative to address various climate protection initiatives.  In...more

Nelson Mullins Riley & Scarborough LLP

Nelson Mullins Tax Report – Senate Passes Inflation Reduction Act

On August 7, 2022, the Senate passed the budget reconciliation bill known as the Inflation Reduction Act. The legislation includes several key tax provisions, and addresses health insurance and prescription drug...more

BakerHostetler

IRS Provides Initial and Limited Guidance on Newly Reinstated ‘Superfund Tax’

BakerHostetler on

Last month, the IRS published Notice 2021-66, issued in response to the Infrastructure Investment and Jobs Act’s (Jobs Act) reinstatement of the previously expired “Superfund Tax”—an excise tax imposed on manufacturers,...more

McDermott Will & Emery

Weekly IRS Roundup May 10 – May 14, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 10, 2021 – May 14, 2021... May 10, 2021: The IRS issued Revenue Procedure 2021-25,...more

McDermott Will & Emery

Weekly IRS Roundup February 8 – February 12, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 8, 2021 – February 12, 2021... On February 9, the Internal Revenue Service announced...more

McDermott Will & Emery

Weekly IRS Roundup January 11 – January 15, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 11, 2021 – January 15, 2021... January 11, 2021: The IRS released TD 9948 containing...more

Proskauer - Not for Profit/Exempt...

10 Keys to Excise Tax on Executive Compensation Paid by Tax-Exempt Organizations

Proposed Regulations under Section 4960 of the Internal Revenue Code provide important guidance for tax-exempt organizations and their affiliates regarding an excise tax on certain executive compensation. The U.S. Department...more

Snell & Wilmer

New IRS Guidance Throws a Pass to Certain Universities That Pay Coaches Compensation in Excess of $1,000,000

Snell & Wilmer on

In Notice 2019-09 (“Notice”), the IRS provides relief from the new excise tax to certain colleges and universities that pay their “covered employees” more than $1 million per year or pay excess parachute payments....more

Seyfarth Shaw LLP

Good News / Bad News: The IRS has Released Interim Guidance Regarding the New Excess Compensation Excise Tax Applicable to...

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Just in time for the New Year and notwithstanding the government shutdown, on December 31, 2018, the Internal Revenue Service (“IRS”) issued Notice 2019-09 (the “Notice”), which provides interim guidance on the new excise tax...more

Bricker Graydon LLP

TCJA excise tax on excess executive compensation for nonprofits

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Beginning with the 2018 tax year, nonprofit organizations that pay their top executives more than $1 million per year are subject to a new 21 percent excise tax. ...more

King & Spalding

IRS Provides Guidance Regarding 21% Excise Tax on Tax-Exempt Organizations for Excessive Executive Compensation

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The Tax Cuts and Jobs Act imposes a 21 percent excise tax on charitable hospitals and other tax-exempt organizations that pay excess remuneration or excess parachute payments to certain highly-compensated employees. On...more

McDermott Will & Emery

Weekly IRS Roundup December 31, 2018 – January 4, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 24, 2018 – January 4, 2019. Tax news is very limited because of the government shut...more

Carlton Fields

IRS Issues Interim Guidance On Certain 2017 Tax Act Changes Affecting Exempt Organizations: Excess Remuneration and Parachute...

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The IRS issued Notice 2019-09, which provides interim guidance in a fairly lengthy Q&A format relating to Code Section 4960, enacted on December 22, 2017....more

Bradley Arant Boult Cummings LLP

COST Weighs-In on Alabama DOR’s Analysis of Federal Tax Reform - SALT Alert: Alabama Edition

On July 31, the Alabama Department of Revenue (ADOR or Department) released its long-awaited and quite comprehensive analysis of the impact of the Tax Cuts and Jobs Act of 2017 (otherwise known as “federal tax reform”) on...more

Vedder Price

Tax Reform’s Impact on Transportation Finance Transactions

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New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more

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