On February 27, 2025, FinCEN confirmed that it would halt enforcement actions in relation to the Corporate Transparency Act (“CTA”) while it developed revised regulations that would prioritize reporting for “those entities...more
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