RECENT EPISODES

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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A SERIES ON TAX POLICY

The Taxing Issues webinar series will further the mission of Tax Analysts: to shed light on tax policy and administration by conducting timely reporting on tax issues, uncovering documents, and encouraging informed debate. The series focuses on public dialogues about cutting-edge issues in federal, state, and international tax policy and administration. We are committed not only to producing high-quality publications, but also to providing open discussion forums featuring top-flight speakers who frame and debate tax-related issues.

Our attendees come from all segments of the tax community and bring engaging questions to these conversations, challenging speakers to defend their views. Registration for our webinars is available to anyone wishing to gain insight from industry experts on timely topics affecting the tax community.

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