Brian H. Jenn
Subscribe to Brian H. Jenn's PostsBrian H. Jenn focuses his practice on US and international tax matters for US and foreign multinationals and other clients. As former Deputy International Tax Counsel (DITC) for the US Department of Treasury, Brian has extensive experience and insight on the Tax Cuts and Jobs Act (TCJA), having been deeply involved in the process of issuing proposed and final regulations and other guidance implementing the TCJA. Brian also has significant insights on taxation of the digital economy, transfer pricing and US taxation of foreign currencies. Read Brian Jenn's full bio.
Potential refund opportunity of buyback excise tax based on § 4501 final regulations
By Shawn O’Brien, Brian H. Jenn, Edward L. Froelich, Nick Ryan and Matthew J. Blaney on Dec 15, 2025
Posted In IRS Guidance, Tax Refunds
Taxpayers who paid the stock repurchase excise tax based on prior guidance provided in Notice 2023-2 and the proposed regulations under Internal Revenue Code (IRC) § 4501 may be entitled to a refund based on changes made in the recently issued IRC § 4501 final regulations. On November 21, 2025, the US Department of the...
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