The excise tax imposes a 1% tax on publicly traded US corporations on the value of any of its stock that is repurchased by the corporation (or certain of its affiliates) during the tax year, effective for certain stock repurchases made after 31 December 2022.
Two sets of proposed regulations addressing the application of the Section 4501 excise tax on certain repurchases of corporate stock (the excise tax) were published on 12 April in the Federal Register (the proposed regulations). With some notable exceptions, these rules adopt much of the preliminary guidance set forth in Notice 2023-2 (the notice), while also providing long-awaited compliance rules on the filing and payment of the excise tax.