Excise Tax on Stock Repurchases Under Current Tax Law and Impact of New IRS Proposed Regulations
Dividend Treatment, Substantiation Requirements, M&A Issues, Challenges for Certain Capital Markets, Notice 2023-2
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE webinar will guide tax counsel and advisers on critical provisions regarding stock repurchases in the Inflation Reduction Act of 2022 (the Act) and the impact of new IRS proposed regulations. The panel will discuss the new IRS regulations for the excise tax on stock repurchases under Section 4501, excise tax base, the netting rule, valuation, timing rules, and calculating and paying the excise tax. The panel will also discuss tax implications for M&A, capital markets transactions, and foreign-parented groups, as well as other vital items significantly impacting transactions.
Outline
- Excise tax for stock repurchases
- Key provisions under current tax law
- Notice 2023-2
- New IRS proposed regulations
- Companies subject to the excise tax
- Timing rules
- Valuation methods
- Calculating and reporting
- Implications for M&A and capital markets transactions, and foreign-parented groups
- Best practices for tax counsel and advisers
Benefits
The panel will discuss these and other key issues:
- Key tax provisions regarding stock repurchases
- Determining what entities are covered under the proposed regulations
- Navigating netting and timing rules and substantiation requirements
- Challenges for structuring M&A transactions
- Issues for foreign-owned U.S. corporations
- Best practices for tax advisers and M&A counsel
Faculty
James Maynor
Shareholder
Greenberg Traurig
Mr. Maynor focuses his practice on the U.S. taxation of international transactions and investments. He advises public... | Read More
Mr. Maynor focuses his practice on the U.S. taxation of international transactions and investments. He advises public companies and privately held businesses on the U.S. tax consequences of mergers and acquisitions, business formations, internal restructurings, spin-offs, divestitures, joint ventures, and capital markets transactions — primarily in the cross-border context. He also advises clients in connection with the formation and structuring of investment funds, with a focus on the U.S. tax issues that are relevant to non-U.S. investors in such funds. In addition, Mr. Maynor advises multinational enterprises on the U.S. tax issues associated with the global immigration and mobility of executives and employees.
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David Strong, CPA
Partner
Crowe
Mr. Strong is a leader in the delivery of tax accounting services related to inventory valuation, accounting method... | Read More
Mr. Strong is a leader in the delivery of tax accounting services related to inventory valuation, accounting method issues, tax controversy, and corporate planning and consultation. He has more than 20 years of experience and specializes in monitoring legislative and regulatory changes for communication to firm management. Mr. Strong has also worked extensively with both publicly traded and privately held companies providing tax compliance and consulting services.
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