Tax Implications of the Inflation Reduction Act: Corporate AMT, Stock Repurchase Excise Tax, Impact on M&A Transactions

A live 90-minute premium CLE/CPE video webinar with interactive Q&A

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Wednesday, October 26, 2022

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, September 30, 2022

or call 1-800-926-7926

This CLE/CPE webinar will guide tax counsel and advisers on critical provisions of the Inflation Reduction Act of 2022 (the Act) and their impact on specific corporate transactions, operations, and tax planning. The panel will discuss the new corporate alternative minimum tax, the excise tax on stock repurchases, and other vital items significantly impacting M&A transactions and other tax rules and challenges under the Act.

Description

On Aug. 16, 2022, the Act was signed into law. The Act provides significant tax provisions impacting small businesses and corporations across various industries. Attorneys and tax professionals must recognize the impact of new tax provisions under the Act, how they are applied to taxpayers, and their effects on certain M&A transactions and tax planning.

The Act includes a variety of tax rules. The two primary tax provisions impacting M&A transactions, deal structures, and tax planning are (1) the new corporate alternative minimum tax imposed on certain corporations meeting a test based on their average annual adjusted financial statement income and (2) an excise tax imposed upon stock repurchases by publicly traded corporations.

The Corporate AMT is a tax of 15 percent on "adjusted financial statement income" rather than "adjusted taxable income" and becomes effective after Dec. 31, 2022. In addition, the Act will impose a one percent excise tax on specific repurchases of a corporation's stock during the taxable year. The stock repurchase excise tax is charged on the fair market value of the repurchased stock, reduced by the fair market value of such corporation's stock issued in the same taxable year. The new tax rules bring about various considerations, such as entities subject to the corporate AMT and excise tax, how they are calculated, available exceptions, and other crucial concerns.

Listen as our panel discusses the new corporate AMT, the excise tax on stock repurchases, and other critical matters impacting M&A transactions and other tax rules and challenges under the Inflation Reduction Act.

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Outline

  1. Overview of the impact of the Inflation Reduction Act on M&A transactions
  2. New corporate AMT
    1. Which companies are subject to the corp AMT?
    2. How do you calculate corporate AMT?
    3. Exceptions
  3. New excise tax for stock repurchases
    1. Key provisions under the Act
    2. Companies subject to the excise tax
    3. Application to specific transactions?
    4. Exceptions
  4. Other key tax provisions under the Act
  5. Tips and techniques for tax counsel in light of the Act

Benefits

The panel will discuss these and other key issues:

  • Key tax provisions of the Act
  • Challenges for structuring M&A transactions in light of the Act
  • Impact of new stock repurchase excise tax
  • Impact of the new corporate AMT
  • Issues for foreign-owned U.S. corporations
  • Best practices for tax and M&A counsel in light of the Act

Faculty

Wainwright, Ronald
Ronald G. Wainwright, Jr., CPA

Partner, Tax Credits & Incentives Advisory
Cherry Bekaert

Mr. Wainwright has more than 25 years of tax advisory experience and works with multi-national, public and closely...  |  Read More

Zarin, Richard
Richard S. Zarin

Partner
Morgan, Lewis & Bockius

Mr. Zarin provides counseling on tax matters involving international and domestic transactions, including mergers and...  |  Read More

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Early Discount (through 09/30/22)

You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.

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