On April 12, 2024, the Department of the Treasury and the IRS published proposed regulations regarding the application of the stock repurchase excise tax under § 4501 of the Internal Revenue Code (the “Proposed Regulations”). The Proposed Regulations largely retain the approach set forth in Notice 2023-2 that was issued on December 27, 2022, which constituted prior interim guidance with respect to the stock repurchase excise tax (the “Notice”), but with certain modifications.
Source: Insights into the Latest Treasury and IRS Proposed Regulations on Excise Tax for Corporate Stock Repurchases