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Excise Tax Internal Revenue Service Corporate Taxes

Dechert LLP

Stock Repurchase Excise Tax Regulations Finalized: Effect on RICs

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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

Wilson Sonsini Goodrich & Rosati

Treasury and the IRS Issue Proposed Regulations Regarding the Stock Buyback Excise Tax

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

Eversheds Sutherland (US) LLP

IRS issues transitional guidance regarding reporting and paying the stock buyback tax

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

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...

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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

Holland & Knight LLP

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

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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

Wilson Sonsini Goodrich & Rosati

Treasury and the IRS Release Interim Guidance on the One-Percent Excise Tax on Stock Repurchases by Publicly Traded Companies

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

Skadden, Arps, Slate, Meagher & Flom LLP

New Corporate Minimum Tax and Stock Repurchase Tax Will Take Effect in 2023, but Questions Remain

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

Akerman LLP

President Biden Signs the Inflation Reduction Act into Law

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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

Dorsey & Whitney LLP

Inflation Reduction Act: New U.S. Excise Tax on Stock Repurchase Transactions Applicable to Certain Canadian Companies

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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

Dorsey & Whitney LLP

Inflation Reduction Act: New Excise Tax Discourages Stock Repurchase Transactions

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​​​​​​​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

Davies Ward Phillips & Vineberg LLP

U.S. Climate Change and Healthcare Bill Moves Democrats’ Tax Policy Forward

The Inflation Reduction Act of 2022 (Act), which was signed into law on August 16, is intended to fight inflation and address climate change. The Act provides for over $360 billion in energy- and climate-related investments,...more

Wilson Sonsini Goodrich & Rosati

Inflation Reduction Act Signed into Law: Important Tax Provisions and Energy Incentives You Need to Know

On August 12, 2022, the U.S. House of Representatives approved H.R. 5376, the "Inflation Reduction Act" (the Act), which was signed into law by President Biden on August 16, 2022. The approval and subsequent enactment follow...more

Lowenstein Sandler LLP

Inflation Reduction Act Tax Implications

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The President is expected to imminently sign the Inflation Reduction Act of 2022 (the “Act”), which was passed by both the Senate and House of Representatives. This Client Alert addresses two main tax provisions in the...more

Polsinelli

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

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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

Paul Hastings LLP

U.S. Senate Passes Inflation Reduction Act

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On August 7, after weeks of negotiations, the Senate voted 51-50 to pass a budget reconciliation package known as the Inflation Reduction Act (the “Bill”), introduced by Senators Joe Manchin (D‑WV) and Chuck Schumer (D‑NY) in...more

Troutman Pepper

Even More Federal and State Tax Filing and Payment Deadlines Extended in Response to COVID-19 Emergency - FAQs on Guidence

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In Notice 2020-23, released on April 9, the Department of the Treasury expanded the relief offered in earlier notices to apply to a broader set of taxpayers, additional tax returns and tax payments required to be filed or...more

Snell & Wilmer

The Pass-Through Income Deduction for Charitable Remainder Trusts

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On January 18, 2019, the Internal Revenue Service (IRS) issued final regulations implementing the new pass-through income deduction for qualified business income (QBI) received from pass-through entities (such as sole...more

Proskauer - Employee Benefits & Executive...

New Excise Tax For Tax-Exempts Can Ensnare For-Profit Employers: Comment Deadline Fast Approaching

As discussed, the IRS’s initial interpretation of a new excise tax under Section 4960 of the Internal Revenue Code could catch for-profit employers who set up foundations, trusts, PACs, and other tax-exempt entities off...more

Holland & Knight LLP

IRS Notice Provides Guidance for Exempt Organizations on Excise Tax

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• The Internal Revenue Service (IRS) released IRS Notice 2019-09 (Notice) offering guidance under Section 4960 of the Internal Revenue Code as added by the Tax Cuts and Jobs Act. • Section 4960 applies to certain...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

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

Bowditch & Dewey

Trump’s Tax Reform: Effect on Nonprofits

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The Administration’s frenzy to pass “tax reform” created tax breaks for some—I’m looking at you, the Trump family—increased taxes for others, and confusion for everyone, at least until the IRS is able to promulgate official...more

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