Nick Ryan
Subscribe to Nick Ryan's PostsNick Ryan focuses his practice on US and international tax matters that arise during internal restructurings, securitizations, mergers and acquisitions, and other strategic transactions. In particular, he advises public and private clients on various tax aspects of cross-border and domestic transactions, including Section 988 transactions, cross-currency hedging, debt refinancing, foreign-derived intangible income deductions, Subpart F income, and foreign tax credits. Read Nick Ryan'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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