KPMG report: Recent developments in taxation of financial products

A KPMG report that discusses recent developments pertinent to taxation of financial products

A KPMG report that discusses developments pertinent to taxation of financial products

KPMG LLP professionals prepared a December 2022 report* [PDF 131 KB] that discusses the following recent developments pertinent to the taxation of financial products: the newly enacted stock buyback transactions 1% excise tax under section 4501, Internal Revenue Service Legal Memorandum 202224010 in which the Office of Chief Counsel concluded that section 1234A applies to merger termination fees, and the Tax Court’s decision in Deitch v. Commissioner that considered the tax characterization of a loan with certain equity-like features.

*This article appears in the Journal of Taxation of Financial Products (Volume 19 Issue 3) and is provided with permission.


The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.