Treasury Redeems Complex Proposed Excise Tax Regulations

On November 21, 2025, Treasury and the IRS released final regulations (the Final Regulations) governing the 1% excise tax on corporate stock repurchases enacted by the Inflation Reduction Act of 2022. These final rules mark a significant shift from the proposed rules (the Proposed Regulations)¹, narrowing the scope of transactions subject to the excise tax and providing much-needed clarity for public companies, private equity firms, and multinational groups. This alert summarizes the key changes, highlights practical implications, and offers actionable guidance for taxpayers, including those that adopted the Proposed Regulations or earlier guidance.²

Stock Repurchase Excise Tax: The Basics