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Liquidation U.S. Treasury

Proskauer - Tax Talks

Final Regulations Issued for Certain Partnership Related Party Basis Adjustment Transactions

Proskauer - Tax Talks on

On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more

Mintz - Securities & Capital Markets...

Proposed Treasury Regulations Provide Guidance on Stock Buyback Excise Tax for Redemptions and M&A Transactions

On April 12, 2024, the Treasury Department and Internal Revenue Service (IRS) issued proposed Treasury Regulations (REG-115710-22) providing comprehensive guidance for applying the one-percent excise tax owed on corporate...more

Holland & Hart LLP

Why Bankruptcy Is A Budding Alternative For Cannabis Cos.

Holland & Hart LLP on

Bankruptcy can be a remarkable tool for rehabilitating a struggling business, preserving jobs and going-concern value, and liquidating the assets of an insolvent company. The drafters of this country's bankruptcy laws...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

WilmerHale

New Stock Buyback Tax: Some Questions Answered, Others Remain

WilmerHale on

One of the headline tax changes in the Inflation Reduction Act of 2022, Public Law 117-169, is a 1% excise tax on stock repurchases by public companies. New Section 4501 of the Internal Revenue Code applies a non-deductible...more

ArentFox Schiff

Initial IRS Guidance on the Stock Repurchase Excise Tax is a Mixed Bag for SPACs

ArentFox Schiff on

The Inflation Reduction Act of 2022, which was signed into law on August 16, 2022, enacted a new 1% excise tax on certain repurchases of the stock of publicly traded corporations, codified in Section 4501 of the Internal...more

Holland & Knight LLP

Venezuela Update: November 19, 2019

Holland & Knight LLP on

The U.S. Department of the Treasury on Oct. 21, 2019, renewed for three months a license granted to several U.S. oil companies so that they may continue operating in the country until Jan. 22, 2020. Chevron is the only...more

Alston & Bird

Killing the Killer B: The Treasury and IRS Issue a Sixth Set of Rules on Killer B Transactions

Alston & Bird on

On December 2, 2016, the Treasury issued Notice 2016-73, describing future regulations that will modify the Killer B regulation issued in 2011; the modifications will stymie newly discovered variations of the Killer B...more

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