On December 27, 2022, the U.S. Department of the Treasury and the Internal Revenue Service issued Notice 2023-2 (the Notice), announcing their intention to issue proposed regulations addressing the application of the new one percent excise tax on certain stock repurchases and economically similar transactions undertaken by publicly traded U.S. corporations and certain foreign corporations. The Notice serves as interim guidance that may be relied upon by taxpayers pending issuance of final regulations.
