U.S. Tax Review: Stock Buyback Tax Regulations, IRS Guidance Plan, and 2023 APA Report

By: Larissa B. Neumann , Julia Ushakova-Stein , Michael Knobler

In this installment of U.S. Tax Review, tax partners Larissa Neumann, Julia Ushakova-Stein and Mike Knobler discuss new regulations regarding the stock buyback tax, the Tax Court’s invalidation of a regulation for failure to address commentators’ objections, the IRS priority guidance plan, the IRS 2023 advance pricing agreements report, BEPS Action 6 Peer Review and Section 987 Regulation Comments.

Read the full commentary and analysis in Tax Notes.