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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

Inflation Reduction Act imposes a nondeductible 1% excise tax on certain corporate stock buybacks

​​​​​​​On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the provisions of the IRA is a nondeductible 1% excise tax on the repurchase of corporate stock (the Buyback...more

Biden’s second (attempted) bite at the private equity apple: Key 2023 Green Book proposals impacting private equity funds and...

On March 28, 2022, the Biden Administration released the 2023 Fiscal Year Budget (the Budget) followed by the release of the Treasury’s Green Book, which provides explanations of the Biden Administration’s revenue proposals....more

Billionaires, BEAT, and Basis-Shifting: 2023 Green Book proposes tax changes affecting corporations, partnerships and individuals

On March 28, 2022, the Biden Administration released the 2023 Fiscal Year Budget (the 2023 Budget). It is important to note that the Budget assumes the Build Back Better Act (the BBBA) will be enacted as passed by the House...more

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