The Advocate General’s opinion on the CFC Finco exemption state aid case, new US regulations and an update on Pillar Two are among the developments in this month’s review by Tim Sarson (KPMG).
US: release of guidance on new 1% excise tax on repurchases of corporate stock
On 9 April 2024 the US Treasury department released two proposed sets of regulations (REG-115710-22 and REG-118499-23) addressing the new non-deductible 1% excise tax on repurchases of corporate stock made after 31 December 2022.
The proposed regulations set forth procedural guidance on the reporting and payment requirements of the new tax. They also address the application of the tax to US subsidiaries of publicly-traded foreign corporate parents: these differ from the rules contemplated by the initial guidance in Notice 2023-2 (the Notice) which significantly expanded the scope of the excise tax with respect to foreign corporations. In other respects the...
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The Advocate General’s opinion on the CFC Finco exemption state aid case, new US regulations and an update on Pillar Two are among the developments in this month’s review by Tim Sarson (KPMG).
US: release of guidance on new 1% excise tax on repurchases of corporate stock
On 9 April 2024 the US Treasury department released two proposed sets of regulations (REG-115710-22 and REG-118499-23) addressing the new non-deductible 1% excise tax on repurchases of corporate stock made after 31 December 2022.
The proposed regulations set forth procedural guidance on the reporting and payment requirements of the new tax. They also address the application of the tax to US subsidiaries of publicly-traded foreign corporate parents: these differ from the rules contemplated by the initial guidance in Notice 2023-2 (the Notice) which significantly expanded the scope of the excise tax with respect to foreign corporations. In other respects the...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
