Published by TaxNotes
The IRS and Treasury abandoned the embattled “funding rule” in final regulations implementing the 1 percent excise tax on stock buybacks and made welcome changes for reorganizations and preferred stock, tax advisers said. The final regulations (T.D. 10037) released November 21 take a different approach in several areas from the proposed regulations (REG-115710-22) issued in April 2024. The new rules will take effect November 24.
A&M's Mark Schneider underscores just how meaningful these changes are for corporations navigating acquisitive reorganizations. Schneider notes that, in the proposed regulations, taxpayers strongly pushed back on how M&A transactions were being swept into the buyback tax.
“The government ultimately concluded that the rule was better focused on ongoing, traditional stock buyback transactions, and not necessarily ones connected to a corporate life event,” Schneider said. “As a policy matter, it’s a reasonable outcome.”
READ THE FULL ARTICLE
Budget 2026-27 | Why buyback taxation a victory for minority shareholders and a hurdle for promoters
February 4, 2026
While promoters may find the new tax rates less attractive than the pre-2024 era, the retail and institutional investor community will likely welcome the lower, more transparent capital gains rates.
Indonesia’s PMK No. 112 of 2025: Procedures for Implementing Double Taxation Avoidance Agreements
February 3, 2026
PMK 112 of 2025 sets Indonesia’s DTAA procedures, CoD rules, DGT Form updates, anti‑abuse tests (LOB, PPT), PE guidance, and 10‑day validation timelines.
A&M Tax Policy Quarterly Outlook: Q4 2025
January 30, 2026
Global Tax Policy Q4 2025: Digital economy, SEP vs. Pillar One, TP disputes, OECD MTC remote work PE, Pillar Two SbS safe harbors, and key regional updates.
Thailand’s Renewed BOI Incentives: A Strategic Window for Growth, Expansion, and Investment (2026–2027)
January 29, 2026
On 15 January 2026, the Thailand Board of Investment (BOI) announced a refreshed set of investment promotion measures for companies evaluating expansion opportunities or strategic joint ventures in Thailand.
