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Proposed Senate Legislation Would Impose Corporate Minimum, Excise Taxes; Increase Funding for IRS

On August 7, 2022, the Senate passed the Inflation Reduction Act of 2022 (the “Act”) that, among other provisions:

i. Establishes a new 15% corporate alternative minimum tax for certain large corporations based on adjusted financial statement income,

ii. Establishes an excise tax on public company corporate stock buybacks, and

iii. Increases IRS funding.

In contrast, the Act does not include the proposal included in the original bill to expand the special holding period rules applicable to carried interest, which was discussed in our previous Alert.

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Treasury, IRS Announce Relief for Securities Lenders


Time to Read: 1 minutes Practices: Tax

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Today, the U.S. Department of the Treasury ("Treasury") and the Internal Revenue Service ("IRS") announced relief for securities lenders who potentially had been subject to taxable capital gains and disallowance of losses from lending their securities to Lehman Brothers and its affiliates, which could not return the securities due to bankruptcy. Last week, Ropes & Gray had requested guidance for these lenders from Treasury and the IRS, and we are pleased with today's announcement. To read our request for guidance, please click here; to read the announced guidance, please click here. If you have questions related to the new guidance, please contact Rom Watson or your usual Ropes & Gray advisor.

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