KPMG report: Stock repurchase excise tax and funding rule considerations for inbound taxpayers
Uncertainty regarding how the funding rule applies, how the government may attempt to resolve uncertainty in future guidance
Funding rule considerations for inbound taxpayers
Publicly traded “inbound” taxpayers need to consider the potential application of the new stock buyback excise tax to share repurchases by a publicly traded foreign parent under the “funding rule” of Notice 2023-2 [PDF 313 KB].
Read a March 2023 report [PDF 233 KB] prepared by KPMG LLP that describes the significant uncertainty regarding how the funding rule applies and how the government may attempt to resolve this uncertainty in future guidance.
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