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
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Contributor(s): Wang, S. Eric | Lloyd, Jameson S | Owen, Alexei L.
Material type: 
ArticleSubject(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 235/2024/2 Journal of Taxation of Investments | OP 235/2024/3 Journal of Taxation of Investments | OP 235/2024/3-1 Planning before the fall | OP 235/2024/3-2 Ins and Outs of the New Proposed Regulations on the Stock Buyback Tax | OP 235/2024/3-3 IRS Adds Several Tax Traps Aimed at Wealthy Individuals to 2024 Dirty Dozen Campaign | OP 235/2024/4 Journal of Taxation of Investments | OP 235/2024/4-1 Connelly v. United States |
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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