Primer on the Stock Repurchase Excise Tax

This program provides a comprehensive overview of the 1% excise tax on stock repurchases (the "Excise Tax") introduced by the Inflation Reduction Act of 2022. Led by Ms. Garofalo and Mr. Colonna, this presentation analyzes the current regulatory landscape, including Treasury and IRS guidance implementing the Excise Tax provisions. The course offers a structured analytical framework for evaluating transactions that may trigger the tax, along with practical considerations for compliance and planning. Through examination of the technical requirements and procedural aspects of the Excise Tax, attendees will develop the knowledge needed to identify potential tax obligations, implement appropriate compliance measures, and advise clients on transaction structuring to navigate this complex area of tax law.

Learning Objectives:

1. Analyze the fundamental components of the 1% excise tax on stock repurchases, including its legislative background and current regulatory framework
2. Identify specific transactions that qualify as stock repurchases for purposes of the Excise Tax in both domestic and foreign contexts
3. Evaluate potential exceptions and limitations to the Excise Tax to determine when the tax applies to particular corporate actions
4. Implement appropriate procedural and compliance requirements related to the Excise Tax, including reporting obligations and payment procedures
5. Develop practical strategies to assist clients in navigating transactions potentially subject to the Excise Tax while avoiding common compliance pitfalls