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Abstract: 

The Inflation Reduction Act has tax implications for both domestic and multinational corporations. The excise tax on corporate stock repurchases is both novel and surprising, but less so than the 15 percent corporate minimum tax on book income, which fails to align in important ways with OECD efforts to establish a global minimum tax in accordance with the so-called “Pillar Two” OECD proposal. Increased IRS funding is likely to improve customer service but also to increase the volume of tax controversies and the amount of tax controversy work for tax practitioners. And the sheer magnitude of green energy credits is likely to be both transformative and disruptive to the now booming green energy industry.

Keywords: corporate minimum tax, adjusted book income, corporate stock buy-backs, IRC Sec. 4501, IRC Sec.461(1), green energy tax credits, refundability and transferability of tax credits, Superfund excise taxes

Affiliations:  1: BakerHostetler.