Introduction
On April 12, 2024, the U.S. Department of the Treasury (the
Treasury) and the U.S. Internal Revenue Service (IRS) published two
sets of proposed regulations (the Proposed Regulations) regarding
the 1% stock repurchase excise tax (the Excise Tax) imposed under
Section 4501 of the U.S. Internal Revenue Code (the Code), with one
set of Proposed Regulations addressing general aspects of the
Excise Tax (the General Proposed Regulations) and one set of
Proposed Regulations addressing procedural aspects of the Excise
Tax (the Procedural Proposed Regulations). On July 3, 2024, the
Treasury and the IRS published final regulations addressing
procedural aspects of the Excise Tax (the Procedural Final
Regulations), which replace the Procedural Proposed Regulations.
Final regulations addressing general aspects of the Excise Tax have
not yet been published.
