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
8/22/2022
/ Acquisitions ,
Alternative Minimum Tax ,
Corporate Taxes ,
Derivatives ,
Excise Tax ,
Inflation Reduction Act (IRA) ,
Mergers ,
Multinationals ,
Publicly-Traded Companies ,
Share Buybacks ,
Share Classes ,
Special Purpose Acquisition Companies (SPACs) ,
Stock Options ,
Stock Repurchases
New regulations expand prior guidance reducing tax benefits of inversions. Proposed debt-equity rules will impact even routine intercompany transactions.
On April 4, 2016, the US Department of the Treasury (Treasury) and...more
4/21/2016
/ Acquisitions ,
Anti-Inversion Regulations ,
Controlled Foreign Corporations ,
Controlled Groups ,
Corporate Taxes ,
De Minimus Quantity Exemption ,
Dividends ,
Foreign Corporations ,
Inversion ,
IRS ,
Multinationals ,
Proposed Regulation ,
Related Parties ,
Stocks ,
U.S. Treasury
Proposed regulations would establish a sweeping framework to treat debt as equity in an effort to curb the use of “excessive” related-party debt.
On April 4, 2016, the US Department of the Treasury (Treasury) and the...more
4/21/2016
/ Affiliates ,
Anti-Avoidance ,
Consolidated Tax Returns ,
Controlled Groups ,
Cross-Border Transactions ,
Debt ,
Dividends ,
Foreign Corporations ,
Income Taxes ,
IRS ,
Proposed Regulation ,
REIT ,
Related Parties ,
Required Documentation ,
Stocks ,
U.S. Treasury ,
Withholding Tax