Notice 2023-2 answers key questions on stock buyback tax Jeff Borghino, Meghan Jodz, Brian Angstadt and Jack Stringfield
Contributor(s): Borghino, Jeff
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Material type: 
ArticleSubject(s): SOCIEDADES ANONIMAS | CONCENTRACION | RECOMPRA DE ACCIONES | IMPUESTOS | ESTADOS UNIDOS
In:
Journal of Taxation of Investments v. 40, n. 2, Winter 2023, p. 3-16Summary: 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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| Artículos | IEF | IEF | OP 235/2023/40/2-1 (Browse shelf) | Available | OP 235/2023/40/2-1 |
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| OP 235/2023/2 Journal of Taxation of Investments | OP 235/2023/3 Journal of Taxation of Investments | OP 235/2023/4 Journal of Taxation of Investments | OP 235/2023/40/2-1 Notice 2023-2 answers key questions on stock buyback tax | OP 235/2023/40/2-2 Private investment funds and foreign currency hedges | OP 235/2023/40/2-3 After 80 years, has the IRS finally succeeded in narrowing Clark's recovery of capital doctrine? | OP 235/2023/40/2-4 SECURE 2.0 Act of 2022 |
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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