N-2023-2: Initial Guidance Regarding the Application of the Excise Tax on Repurchases of Corporate Stock under Section 4501 of the Internal Revenue Code

Notice 2023-2 (1) announces the intent of the Treasury Department and the IRS to issue proposed regulations (forthcoming proposed regulations) addressing the application of the corporate stock repurchase excise tax added to section 4501 of the Internal Revenue Code by the enactment of Public Law 117-169, 136 Stat. 1818 (August 16, 2022), commonly referred to as the Inflation Reduction Act of 2022; (2) describes certain rules and procedures that the Treasury Department and the IRS intend to include in the forthcoming proposed regulations; (3) provides interim guidance that taxpayers may rely upon until the issuance of the forthcoming coming proposed regulations; and (4) solicits comments on the rules contained in the notice and certain other issues prior to the publication of the forthcoming proposed regulations.

Notice 2023-2 will be in IRB: 2023-3, dated January 17, 2023.

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