The new 1 percent excise tax on stock buybacks, established by the Inflation Reduction Act, is designed to curtail incentives for corporations to use stock buybacks to boost share prices. The tax has generated many questions about how it will work, confusing practitioners and concerning taxpayers. What will qualify as a repurchase? How will special purpose acquisition companies be affected? And how will fair market value be determined?
As the OECD continues to plan pillars 1 and 2, some countries have delayed or halted their efforts to conform. While the United States has enacted a 15 percent corporate minimum tax, the tax does not satisfy pillar 2. How viable is this proposed new international tax regime without U.S. participation? Can it work without a U.S. and EU consensus?
President Biden and Congress recently enacted the Inflation Reduction Act, which includes climate incentives and healthcare provisions, along with a 15 percent corporate minimum tax. What are the tax implications of the act, particularly its minimum tax? What are the goals of the new corporate tax? And how does it align with the OECD’s efforts to establish a global minimum tax, particularly the pillar 2 proposal?
Until fairly recently, courts rejected the federal government's interpretation of its regulations in most high-profile transfer pricing cases. But with a string of major wins over the last several years, including Medtronic, Altera, and Coca-Cola, the IRS has reversed that trend. Is the government choosing cases more carefully or using better litigation strategy, or are the courts shifting their views on IRS arguments? Will this trend continue in cases like 3M or Facebook and beyond? How should taxpayers respond?
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