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On 9 April 2024, Treasury released two sets of proposed regulations regarding the excise tax on repurchases of corporate stock under section 4501. The proposed regulations were published in the Federal Register on 12 April 2024. The first set of proposed regulations includes substantive guidance on the excise tax, while the second covers procedural matters including reporting and payment. Comments are due on the procedural matters by 13 May 2024, but taxpayers have until 11 June 2024 to submit comments on the substantive guidance. These rules have a potentially significant impact on publicly traded non-US companies with US affiliates.
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