Notice 2023-2 answers key questions on stock buyback tax / Jeff Borghino, Meghan Jodz, Brian Angstadt and Jack Stringfield
Resumen.
The Inflation Reduction Act introduced a new excise tax on the repurchase of corporate stock that will apply to publicly traded corporations and certain related parties of publicly traded corporations. This novel excise tax is expected to create significant additional considerations for taxpayers when contemplating a variety of M&A transactions that may qualify as a repurchase of stock. In Notice 2023-2 the Internal Revenue Service provided interim guidance that resolves some of the uncertainties based on varying interpretations in the statute, however, many questions remain.
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CONCENTRACION
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IMPUESTOS
ESTADOS UNIDOS
Borghino, Jeff
Journal of Taxation of Investments 0747-9115 v. 40, n. 2, Winter 2023, p. 3-16