On April 12, 2024, the Treasury Department and Internal Revenue Service (IRS) issued proposed Treasury Regulations (REG-115710-22) providing comprehensive guidance for applying the one-percent excise tax owed on corporate stock repurchasesoccurring on or after January 1, 2023 (Stock Buyback Excise Tax). On the same day, a second set of proposed Treasury Regulations was issued (REG-118499-23) that includes procedural rules for reporting and paying the tax, recordkeeping, and penalties (together, the Proposed Treasury Regulations) for such repurchases.
Source: Proposed Treasury Regulations Provide Guidance on Stock Buyback Excise Tax for Redemptions and M&A Transactions