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Proskauer - Tax Talks

Proposed Regulations Issued on the Excise Tax on Repurchases of Corporate Stock

Proskauer - Tax Talks on

On April 9, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (the “IRS”) issued two sets of proposed Treasury Regulations related to section 4501, REG-115710-22, which provides guidance on...more

Holland & Knight LLP

Treasury, IRS Issue Inbound Corporation Stock Repurchase Excise Tax Proposed Regulations

Holland & Knight LLP on

Following the release of initial guidance in the form Notice 2023-2, the U.S. Department of the Treasury (Treasury) and IRS issued proposed regulations (the Proposed Regulations) under the Section 4501 stock repurchase excise...more

Holland & Knight LLP

Treasury Department's First Repurchase Excise Tax Guidance Contains Rotten "Easter Eggs"

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS intend to issue proposed regulations addressing application of a new excise tax on repurchases of corporate stock under Section 4501 of the Internal Revenue Code (Code). Section...more

Dechert LLP

Inflation Reduction Act of 2022: Corporate Alternative Minimum Tax, Excise Tax on Corporate Stock Repurchases, and Business Loss...

Dechert LLP on

On August 12, 2022, the U.S. Congress passed the Inflation Reduction Act of 2022 (the “Act”), which was signed into law by President Biden on August 16, 2022. Alongside sweeping changes to energy, environmental and...more

Bracewell LLP

Straight from the Source: Proposed Regulations Seek to Implement TCJA Changes to Source of Income Rules, Altering Treatment for...

Bracewell LLP on

The source of income is a critical component of U.S. tax rules for both U.S. taxpayers operating internationally (namely, with respect to foreign tax credit planning) and foreign persons with investment or other activity in...more

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