On July 4, 2025, the “One Big Beautiful Bill Act” (OBBBA) became law. The OBBBA makes significant changes to domestic and international tax provisions, including provisions addressing bonus depreciation, research and experimental (R&E) expenditures, the limitation on interest deductibility under Section 163(j), state and local tax (SALT) deductions, expansion of the qualified small business stock
Lucas Giardelli
US Senate Finance Committee Makes Changes to Proposed Section 899
By Julie Burrall, Steven D. Garden, Lucas Giardelli, David Goett, Jared B. Goldberger, Michelle Jewett, Kenneth Klein, Russell E. Nance, Warren S. Payne, Remmelt Reigersman, Sam Riesenberg & Brennan W. Young on
Posted in Tax
The US Senate Finance Committee has released a substitute (the “Senate version”) for the tax provisions of the “One Big Beautiful Bill,” the budget reconciliation bill currently under consideration by Congress. An earlier version of this bill was passed by the US House of Representatives on May 22, 2025 (the “House version”). Our prior Legal…
1% Stock Buyback Tax: US Treasury IRS Release Proposed Regulations
The US Department of the Treasury and the Internal Revenue Service recently issued long-awaited proposed regulations under Section 4501 of the Internal Revenue Code regarding the 1% stock buyback excise tax. The tax applies to stock repurchases and “economically similar transactions” undertaken by publicly traded US (and certain foreign) corporations beginning on January 1, 2023.
Corporate Alternative Minimum Tax: US Treasury, IRS Release Interim Guidance
Posted in Tax
On December 27, 2022, the Treasury Department and the Internal Revenue Service (“IRS”) issued Notice 2023-7 (the “Notice”) describing proposed regulations Treasury intends to issue to address certain aspects relating to the application of a new corporate alternative minimum tax (“CAMT”)—a 15% tax on the adjusted financial statement income (“AFSI”) introduced by the Inflation Reduction…
1% Stock Buyback Tax: US Treasury, IRS Release Interim Guidance
On December 27, 2022, the US Treasury Department and the Internal Revenue Service (“IRS”) issued Notice 2023-2 (the “Notice”), which provides taxpayers interim guidance (until regulations are issued) on how the new 1% excise tax on stock-buybacks will be imposed and administered. The new 1% excise tax was enacted last summer as part of the…
US Inflation Reduction Act – Corporate Minimum Tax and Stock Repurchase Excise Tax
By Jason S. Bazar, Lucas Giardelli, Michael Lebovitz, Warren S. Payne, Remmelt Reigersman, Brennan W. Young & Charlene S. Soleimani on
Posted in Public Policy, Tax
If you thought the recent price increase at your neighborhood store was inflation’s last flop, think again. The Inflation Reduction Act (“IRA”), which was signed into law by President Biden on August 16, 2022, is estimated to raise $739 billion over the decade. The IRA is financed primarily by several targeted tax increases. Revenues will…