Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
How Tax Works - Entity Selection
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JONES DAY PRESENTS®: The Future of Transfer Pricing in Australia: Implications of the Glencore Decision
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New anti-abuse provisions
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This Alert summarizes all the material amendments to Chapter 105 of the North Carolina General Statutes ratified to date during the General Assembly’s 2024 short session....more
On June 28, 2024, the U.S. Department of the Treasury and the Internal Revenue Service issued final regulations on the reporting of the one-percent (1%) stock repurchase excise tax imposed by new section 4501 of the Internal...more
On April 9, 2024, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued long-awaited proposed regulations under Section 45011 relating to the one percent stock buyback excise tax. This...more
In President Biden’s recent State of the Union Address, he called on corporations and wealthy taxpayers to pay their “fair share” through proposals to end tax breaks for private jets, further limit deductions for executive...more
On March 11, 2024, the Biden Administration released the Fiscal Year 2025 Budget, and the “General Explanations of the Administration’s Fiscal Year 2025 Revenue Proposals,” which is commonly referred to as the “Green Book.”...more
Our Federal & International Tax Group covers notable business and individual tax proposals revealed by the Biden Administration in this year’s Green Book....more
On June 29, 2023, the Internal Revenue Service (IRS) issued Announcement 2023-18 (the Announcement), which provides transitional guidance with respect to the stock repurchase excise tax under section 4501 (the Buyback Tax)....more
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
On Friday, 24 March 2023, the Washington Supreme Court upheld the state’s capital gains tax (the WA CGT) in a 7–2 decision, bringing an end to months of uncertainty as a suit to challenge the new tax worked its way through...more
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
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
The “Inflation Reduction Act” introduced Section 4501, which contains a new one percent excise tax on certain stock repurchases and economically similar transactions undertaken by publicly traded U.S. corporations and certain...more
The corporate alternative minimum tax (CAMT) and the excise tax on stock repurchases, each enacted as part of the Inflation Reduction Act of 2022, will soon become effective — for the CAMT, for taxable years beginning after...more
On Tuesday August 16, President Biden signed the Inflation Reduction Act of 2022 into law (the “Act”). The enacted legislation contains several revenue-raising tax provisions detailed below. ...more
On August 23, 2022, the Regular Division of the Oregon Tax Court issued its opinion in Santa Fe Natural Tobacco Co. v. Department of Revenue, State of Oregon. The court determined that the taxpayer in that case is subject to...more
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
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
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
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
On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022, HR 5376 (the “Act”), into law. Among other significant changes, the Act includes a new 1% excise tax on stock repurchase transactions by certain...more
On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022, HR 5376 (the “Act”), into law. Among other significant changes, the Act includes a new 1% excise tax on stock repurchase transactions by...more
On August 16, 2022, President Biden signed into law the Inflation Reduction Act of 2022 (the Act), a sweeping bill with significant tax, energy and healthcare implications...more
On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the provisions of the IRA is a nondeductible 1% excise tax on the repurchase of corporate stock (the Buyback...more
Beginning in 2023, an excise tax of 1% will apply to public company stock buybacks and a 15% corporate minimum tax generally will apply to corporations with book income exceeding $1 billion. Key Points: ..Public...more
On Tuesday, August 16, President Biden signed the Inflation Reduction Act of 2022 (the Act) into law, which includes material changes to various sections of the Internal Revenue Code of 1986, as amended (the Code). The...more