Notice 2023-2 Answers Key Questions on Stock Buyback Tax
Author: Jeff Borghino.; Meghan Jodz.; Brian Angstadt.; Jack Stringfield.
Source: Volume 40, Number 02, Winter 2023 , pp.3-16(14)
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Abstract:
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.Keywords: stock repurchase excise tax, mergers and acquisitions, M&A, Notice 2023-2, IRC Sec. 4501, corporate stock repurchases
Affiliations:
1: Grant Thornton LLP; 2: Grant Thornton LLP; 3: Grant Thornton LLP; 4: Grant Thornton LLP.