In our blog post dated August 22, 2022, we discussed the one percent (1%) excise tax on certain stock repurchase transactions by certain publicly traded corporations enacted as part of the Inflation Reduction Act of 2022 (the...more
3/16/2023
/ Affiliates ,
Anti-Inversion Regulations ,
Canada ,
Foreign Corporations ,
Inflation Reduction Act (IRA) ,
IRS ,
New Guidance ,
Publicly-Traded Companies ,
Stock Repurchases ,
Subsidiaries ,
U.S. Treasury
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
8/23/2022
/ Biden Administration ,
Canada ,
Corporate Taxes ,
Covered Entities ,
Domestic Corporations ,
Excise Tax ,
Foreign Corporations ,
Inflation Reduction Act (IRA) ,
IRS ,
Publicly-Traded Companies ,
Share Buybacks ,
Stock Repurchases ,
U.S. Treasury
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
8/23/2022
/ Biden Administration ,
Corporate Taxes ,
Covered Entities ,
Domestic Corporations ,
Excise Tax ,
Foreign Corporations ,
Inflation Reduction Act (IRA) ,
IRS ,
Publicly-Traded Companies ,
Share Buybacks ,
Stock Repurchases ,
U.S. Treasury
An often overlooked exception to U.S. withholding taxes may result in a lower overall U.S. tax burden.
The Foreign Account Tax Compliance Act (“FATCA”) was enacted in an effort to ensure that U.S. taxpayers could not...more
2/3/2021
/ FATCA ,
Financial Institutions ,
Foreign Financial Accounts ,
Foreign Investment ,
Gross Proceeds ,
IRS ,
Offshore Funds ,
Proposed Legislation ,
Reporting Requirements ,
Tax Evasion ,
Tax Planning ,
U.S. Treasury ,
Withholding Requirements
Challenges of Transferring IP Offshore -
What constitutes intellectual property (“IP”) has long been a contested issue in tax practice, but generally includes intangible assets as wide-ranging as patents, copyrights,...more
4/18/2016
/ Exceptions ,
Foreign Subsidiaries ,
Intra-Group Transactions ,
IRS ,
Patents ,
PFIC ,
Portability ,
Proposed Regulation ,
Royalties ,
Subpart F ,
Tax Reform ,
Transfer of Assets ,
U.S. Treasury