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KPMG report: Initial analysis of stock repurchase excise tax proposed regulations

A report that provides initial analysis of the proposed regulations

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April 17, 2024

The U.S. Treasury Department and IRS on April 9, 2024, released two sets of proposed regulations (REG-115710-22 and REG-118499-23) addressing the non-deductible 1% excise tax on repurchases of corporate stock under section 4501. The proposed regulations largely follow the approach of Notice 2023-2, which provided initial guidance regarding the application of the stock repurchase excise tax , but the proposed regulations provide rules for the application of the excise tax to U.S. subsidiaries of publicly traded foreign corporate parents that differ from those contemplated by Notice 2023-2.

Read an April 2024 report prepared by KPMG LLP that provides initial analysis of the proposed regulations

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