In the context of initial Treasury and IRS guidance, and further to our recent report: “IRS Issues Guidance on IRA Stock Repurchase Excise Tax,” Latham & Watkins’ “Treasury and IRS Issue Initial Guidance on Stock Buyback Tax and Corporate Minimum Tax” illustrates and offers observations about the types of transactions subject to the new stock buyback tax and—where relevant—provides planning and structural recommendations to companies to mitigate the impacts. The memo also addresses and illustrates the application of the corporate alternative minimum tax as applied to different scenarios.
Access additional resources on our Capital Allocation/Capital Structure and M&A, IPOs, Separations and Go-Private Transactions pages. This post first appeared in the weekly Society Alert!