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Ins and Outs of the New Proposed Regulations on the Stock Buyback Tax Davis J. Wang , S. Eric Wang , Jameson S. Lloyd , Alexei L. Owen.

By: Wang, Davis J.
Contributor(s): Wang, S. Eric | Lloyd, Jameson S | Owen, Alexei L.
Material type: ArticleArticleSubject(s): RECOMPRA DE ACCIONES | IMPUESTOS In: Journal of Taxation of Investments n. 41-2, spring 2024, p. 51-62Summary: This article reviews the recently issued Proposed Regulations on the application of the stock repurchase tax in Internal Revenue Code Section 4501. The Proposed Regulations address repurchases of foreign corporate stock “funded” by a domestic entity, repurchases of preferred stock, exemptions for redemptions in a complete liquidation, and application to M&A transactions.
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OP 235/2024/3-2 (Browse shelf) Available OP 235/2024/3-2

This article reviews the recently issued Proposed Regulations on the application of the stock repurchase tax in Internal Revenue Code Section 4501. The Proposed Regulations address repurchases of foreign corporate stock “funded” by a domestic entity, repurchases of preferred stock, exemptions for redemptions in a complete liquidation, and application to M&A transactions.

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