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Interim Guidance on Book-Minimum Tax and Stock Buyback Excise Tax

December 30, 2022

Via: JD Supra

The Treasury Department and the Internal Revenue Service (IRS) released initial guidance on Dec. 27, 2022, concerning two corporate tax increases included in the climate and energy reconciliation bill commonly known as the Inflation Reduction Act (IRA, P.L. 117-169). Notice 2023-2 provides interim guidance with respect to the new excise tax applicable to certain stock repurchases, while Notice 2023-7 provides interim guidance on the new 15% book-minimum tax applicable to certain large corporations. Both notices indicate the Treasury Department’s and the IRS’ intention to issue proposed regulations that will include more comprehensive rules for implementing the new taxes, which take effect starting in 2023. Taxpayers may rely on the interim guidance until final regulations are promulgated.

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