corporate alternative minimum tax/CAMT Archives

corporate alternative minimum tax/CAMT

IRS roundup: September 19 – October 1, 2025

by Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney | Oct 8, 2025 | Appellate Courts, Court Procedure Matters, IRS Guidance, Tax Reform, Transfer Pricing Resource

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for September 19, 2025 – October 1, 2025.

September 19, 2025: The US Department of the Treasury (Treasury) and the IRS issued proposed regulations, providing guidance on the “no tax on tips” provision of the One Big Beautiful Bill Act. The proposed regulations define “qualified tips” and identify which occupations customarily and regularly receive tips on or before December 31, 2024.

September 23, 2025: The IRS issued Notice 2025-54, providing guidance on the 2025 – 2026 special per diem rates for taxpayers when determining their ordinary and necessary business expenses incurred while traveling away from home, including meal and incidental expenses rates, rates for the incidental expenses only deduction, and rates for (and a list of) high-cost localities for purposes of the high-low substantiation method.

September 29, 2025: The IRS issued Revenue Procedure 2025-30, providing updated procedures for taxpayers requesting private letter rulings from the IRS after September 29, 2025, regarding transactions intended to qualify under Internal Revenue Code § 3551. This guidance specially provides details on the representations, information, and analysis taxpayers should submit when requesting these rulings.

September 30, 2025: The IRS issued Notice 2025-46 and Notice 2025-49, providing guidance on the application of the corporate alternative minimum tax (CAMT).

Notice 2025-46 provides interim guidance to domestic corporate transactions, financially troubled companies, and tax consolidated groups. This notice also announces the Treasury and the IRS’s intent to partially withdraw the CAMT Proposed Regulations (described in Section 2.03 of this notice) and instead issue revised proposed regulations with guidance similar to Sections 3 – 6 of this notice. The proposed regulations will reduce compliance burdens related to, and costs associated with, application of the CAMT.

Notice 2025-49 provides interim guidance regarding application of the CAMT as it relates to §§ 55, 56A, and 59. This notice also announced the Treasury and the IRS’s intent to partially withdraw the CAMT Proposed Regulations (described in Section 2.03 of this notice) and instead issue revised proposed regulations with guidance similar to Sections 3 – 10 of this notice.

October 1, 2025: The Treasury and the IRS issued final regulations, providing guidance on interest capitalization requirements on designated property. The final regulations specifically remove the associated property rule (including similar rules in existing regulations), modifies how “improvement” is defined when applying those similar rules, and primarily affects taxpayers making improvements to real or tangible personal property if those improvements are the production of designated property.

October 1, 2025: The US Court of Appeals for the Eighth Circuit released its opinion in 3M Company v. Commissioner. The Eighth Circuit reversed the US Tax Court’s decision that 3M must pay taxes on royalties – that it could not legally receive – from a Brazilian subsidiary and remanded the Tax Court’s decision with instructions to redetermine 3M’s tax liability. Relying [...]

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IRS roundup: July 12 – July 29, 2025

by Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney | Aug 15, 2025 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for July 12, 2025 – July 29, 2025.

IRS guidance

July 15, 2025: The IRS issued Revenue Ruling 2025-14, providing prescribed rates for federal income tax purposes for August 2025, including but not limited to:

Short-, mid-, and long-term applicable federal rates for August 2025 for purposes of Internal Revenue Code (Code) Section 1274(d).

Short-, mid-, and long-term adjusted applicable federal rates for August 2025 for purposes of Code Section 1288(b).

The adjusted federal long-term rate and the long-term tax-exempt rate, as described in Code Section 382(f).

The appropriate percentages for determining the low-income housing credit described in Section 42(b)(1) for buildings placed in service during the current month.

The federal rate for determining the present value of an annuity, an interest for life, a term of years, a remainder, or a reversionary interest for purposes of Code Section 7520.

July 15, 2025: The IRS issued Notice 2025-39, providing guidance on the corporate bond monthly yield curve, corresponding spot segment rates under Code Section 417(e)(3), and the 24-month average segment rates under Code Section 430(h)(2). The notice also provides guidance on the interest rate for 30-year Treasury securities under Code Section 417(e)(3)(A)(ii)(II) (for plan years in effect before 2008) and the 30-year Treasury weighted average rate under Code Section 431(c)(6)(E)(ii)(I).

July 16, 2025: The IRS issued Revenue Ruling 2025-15, clarifying certain withholding and reporting requirements with respect to uncashed retirement plan distribution checks. The IRS held that no adjustment or refund is available under Sections 6413 and 6414 with respect to amounts withheld and remitted when more than the correct amount of tax was not withheld or paid.

July 16, 2025: The IRS issued Notice 2025-40, providing updated static mortality tables for defined benefit pension plans under Code Section 430(h)(3)(A) and Section 303(h)(3)(A) of the Employee Retirement Income Security Act of 1974 (ERISA). These updated static mortality tables apply for purposes of calculating the funding target and other items for valuation dates occurring during the 2026 calendar year.

The notice also includes a modified unisex version of the mortality tables for determining the minimum present value under ERISA Sections 417(e)(3) and 205(g)(3) for distributions with annuity starting dates that occur during stability periods beginning in the 2026 calendar year.

July 21, 2025: The IRS issued Notice 2025-36, identifying and making obsolete 83 Internal Revenue Bulletin guidance documents. The notice cites Executive Order 14192, Unleashing Prosperity Through Deregulation, which directed agencies to identify regulations to be repealed and other guidance that are appropriate for withdrawal. The 83 obsolete regulations span multiple contexts and Code sections.

July 21, 2025: The IRS issued Notice 2025-37, which includes the inflation adjustment factors and applicable amounts for calendar year 2025 for the zero-emission nuclear power production credit under Code Section 45U. It [...]

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IRS Roundup May 15 – June 2, 2025

by Evan Walters, Samuel F. Hamer, Edward L. Froelich, Michael J. Scarduzio and Matthew J. Blaney | Jun 5, 2025 | IRS Guidance, Tax Reform, Trial Courts

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for May 15, 2025 – June 2, 2025.

IRS GUIDANCE

May 15, 2025: The IRS issued Notice 2025-29, providing guidance on the corporate bond monthly yield curve, corresponding spot segment rates under Internal Revenue Code (Code) § 417(e)(3), and the 24-month average segment rates under Code § 430(h)(2). The notice also provides guidance on the interest rate for 30-year Treasury securities under Code § 417(e)(3)(A)(ii)(II) (for plan years in effect before 2008) and the 30-year Treasury weighted average rate under Code § 431(c)(6)(E)(ii)(I).

May 15, 2025: The IRS issued Revenue Ruling 2025-12, providing prescribed rates for federal income tax purposes for June 2025, including, but not limited to:

Short-, mid-, and long-term applicable federal rates for June 2025 for purposes of Code § 1274(d)
Short-, mid-, and long-term adjusted applicable federal rates for June 2025 for purposes of Code § 1288(b)
The adjusted federal long-term rate and the long-term tax-exempt rate, as described in Code § 382(f)
The federal rate for determining the present value of an annuity, an interest for life, or for a term of years, or a remainder or a reversionary interest for purposes of Code § 7520.

May 19, 2025: The IRS released Internal Revenue Bulletin 2025-21. It includes Revenue Procedure 2025-19, which provides the 2026 inflation adjusted amounts for Health Savings Accounts (HSAs) as determined under Code § 223, as well as the maximum amount that may be made newly available for excepted benefit health reimbursement arrangements under Code § 54.9831-1(c)(3)(viii). Revenue Procedure 2025-19 is effective for HSAs for the 2026 calendar year and for excepted benefit health reimbursement arrangements beginning in 2026.

May 22, 2025: The IRS issued a notice to US taxpayers living or working abroad, encouraging them to file their 2024 federal income tax returns by June 16, 2025.

June 2, 2025: The IRS issued Notice 2025-27, providing interim guidance on the application of the corporate alternative minimum tax (CAMT), as well as relief from certain additions to tax for a corporation’s underpayment of estimated tax under Code § 6655. Among other things, this notice also provides an optional simplified method for determining applicable corporation status and waives certain additions to tax under Code § 6655 concerning a corporation’s CAMT liability under Code § 55. The US Department of the Treasury (Treasury) and the IRS also plan on issuing a notice of proposed rulemaking, revising the CAMT proposed regulations in § 2.02(2) of this notice to include a method for determining applicable corporation status.

The IRS also released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums, and Chief Counsel Advice).

TAX CONTROVERSY DEVELOPMENTS

On May 22, 2025, the US Tax Court issued its opinion in Facebook Inc. v. Commissioner.

THE “BIG, BEAUTIFUL BILL”

The “
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Weekly IRS Roundup September 9 – September 13, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | Sep 19, 2024 | IRS Audits, IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 9, 2024 – September 13, 2024.

September 10, 2024: The IRS extended the deadline to file individual and business tax returns and make tax payments for certain individuals and businesses in Connecticut and New York that were affected by severe weather that began on August 18, 2024. The new deadline is February 3, 2025. The extended deadline is available to taxpayers in any area designated by the Federal Emergency Management Agency (FEMA), including individuals and households that reside or have a business in Suffolk County in New York and in Fairfield, Litchfield, and New Haven Counties in Connecticut.

September 11, 2024: The IRS released an updated version of IRS Form 1099-DA and draft instructions for digital asset brokers to report sales and exchanges of digital assets beginning in 2025.

September 11, 2024: The IRS reminded taxpayers of their right to finality under the Taxpayer Bill of Rights and to know the deadlines for challenging IRS decisions and the time limits for the IRS to audit or collect taxes. This right ensures that taxpayers are aware when an audit is concluded and understand the specific timeframes for various tax-related actions.

September 12, 2024: The IRS released Notice 2024-66, which provides relief from the penalty under Internal Revenue Code (Code) § 6655 for underpayments of estimated corporate alternative minimum tax (CAMT) installments by corporations for taxable years beginning after December 31, 2023, and before January 1, 2025. This notice extends and incorporates relief from previous notices, offering additional time for corporations to meet their estimated tax obligations.

September 12, 2024: The IRS reminded taxpayers that the Taxpayer Advocate Service, an independent organization within the IRS, provides free assistance to individuals, businesses, and exempt organizations experiencing financial difficulties or systemic issues that cannot be resolved through standard IRS procedures.

September 13, 2024: The IRS extended the deadline to file federal individual and business tax returns and make tax payments for certain individuals and businesses in Louisiana that were affected by Tropical Storm Francine. The new deadline is February 3, 2025. The extended deadline is available to taxpayers in any area designated by FEMA, including individuals and households that reside or have a business in any Louisiana county.

September 13, 2024: The IRS released proposed regulations that outline the rules for calculating adjusted financial statement income and determining applicable corporation status under the CAMT for tax years starting after 2022. The proposed regulations provide additional guidance on partnership investments, corporate transactions, and foreign tax credits and extend penalty relief for corporations failing to pay estimated CAMT for tax years beginning after December 31, 2023, and before January 1, 2025.

September 13, 2024: The IRS released proposed regulations that exclude Tribal general welfare benefits from gross income under [...]

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Weekly IRS Roundup October 2 – October 6, 2023

by Evan Walters | Oct 16, 2023 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 2, 2023 – October 6, 2023.

October 2, 2023: The IRS released Internal Revenue Bulletin 2023-40, which includes the following:

Revenue Ruling 2023-18 provides the October 2023 applicable federal rates.
Notice 2023-64 provides interim guidance on the new corporate alternative minimum tax (CAMT) and indicates that proposed regulations are forthcoming. The notice describes rules for:
- Determining a taxpayer’s applicable financial statement and adjusted financial statement income (AFSI), including rules applicable to tax consolidated groups and certain foreign corporations
- AFSI adjustments for the depreciation of Section 168 property, the amortization of qualified wireless spectrum, the treatment of certain taxes and to prevent certain duplications and omissions
- Determining the applicable corporation status, the CAMT foreign tax credit and financial statement net operating losses.
Notice 2023-66 updates the corporate bond monthly yield curve, the corresponding spot segment rates for September 2023 used under § 417(e)(3)(D), the 24-month average segment rates for September 2023 and the 30-year Treasury rates, as reflected by the application of § 430(h)(2)(C)(iv).
Revenue Procedure 2023-30 provides specifications for the private printing of red ink substitutes for the 2023 revisions of certain information returns.
Revenue Procedure 2023-31 refers filers to applicable publications, forms, instructions or other guidance, including postings on IRS.gov, for procedures related to seeking a hardship waiver or administrative exemption from requirements to file Forms 8955-SSA and 5500-EZ electronically.

October 3, 2023: A public meeting of the Electronic Tax Administration Advisory Committee will be held on November 15, 2023.

October 5, 2023: The IRS warned high-income taxpayers to avoid promotions involving inflated deductions for art donations. The IRS indicated that schemes involving abusive art donations are on its radar and that multiple investigations are underway.

October 6, 2023: The IRS released proposed regulations addressing so-called “Killer B” transactions. These transactions, at a high level, are structured to repatriate foreign subsidiary earnings through triangular reorganizations. The proposed regulations would formalize and modify guidance set forth in Notices 2014-32 and 2016-73.

October 6, 2023: The IRS issued proposed regulations, Revenue Procedure 2023-33 and frequently asked questions on the transfer of new and previously owned clean vehicle credits from a taxpayer to an eligible entity for vehicles placed in service after December 31, 2023. This guidance addresses how taxpayers can elect to transfer new and previously owned clean vehicle credits to dealers who are eligible to receive advance payments of either credit, how dealers can become eligible entities to receive advance payments of new or previously owned clean vehicle credits and how to recapture the credit.

October 6, 2023: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Weekly IRS Roundup September 11 – September 15, 2023

by Evan Walters | Sep 19, 2023 | IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 11, 2023 – September 15, 2023.

September 11, 2023: The IRS released Internal Revenue Bulletin 2023-37, which includes the following:

Revenue Ruling 2023-16 provides the applicable federal rates for September 2023.
Revenue Ruling 2023-17 sets forth the underpayment and overpayment interest rates under Code Section 6621 for the calendar quarter beginning October 1, 2023.
Revenue Procedure 2023-29 provides the applicable percentage table used to calculate the premium tax credit under Code Section 36B.
Notice 2023-62 announces a two-year administrative transition period with respect to the requirement under Code Section 603 that catch-up contributions made on behalf of certain eligible participants be designated as Roth contributions. The notice also requests comments for further guidance with respect to Code Section 603.
Announcement 2023-25 and Announcement 2023-26 revoke tax-exempt classification for specified organizations.
Announcement 2023-28 corrects citations in Revenue Procedure 2023-27.

September 12, 2023: The IRS released Notice 2023-64, which provides interim guidance on the corporate alternative minimum tax (CAMT). The notice lists financial statements that meet the definition of an applicable financial statement, provides general rules for determining “financial statement income” and includes guidance on when corporations are subject to the CAMT. Notice 2023-64 supplements and clarifies Notice 2023-07 and Notice 2023-20.

September 12, 2023: The IRS released Revenue Procedure 2023-31, providing guidance on Form 8955-SSA, Annual Registration Statement Identifying Separated Participants With Deferred Vested Benefits, and Form 5500-EZ, Annual Return of A One-Participant (Owners/Partners and Their Spouses) Retirement Plan or A Foreign Plan, which must be filed for plan years beginning on or after January 1, 2024. Revenue Procedure 2023-31 supersedes Revenue Procedure 2015-47.

September 12, 2023: The IRS published Tax Tip 2023-110, advising taxpayers to look out for scammers posing as charities and to ensure their donations are going to legitimate charitable organizations.

September 13, 2023: The IRS extended tax relief to individuals and businesses impacted by Hurricane Idalia in 28 counties in Georgia. As a result, affected individuals filing personal income tax returns on extensions expiring October 16, 2023, calendar-year partnerships and S corporations whose extensions expire on October 16, 2023, and calendar-year corporations whose 2022 extensions expire on November 15, 2023, now have until February 15, 2024, to file returns and pay related taxes.

September 14, 2023: The IRS announced an immediate moratorium through at least the end of the year on processing new claims for the Employee Retention Credit (ERC). The moratorium is in response to promoters who have aggressively marketed the credit to businesses without regard for their eligibility. Hundreds of criminal cases related to ERC claims are being worked, [...]

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Weekly IRS Roundup June 5 – June 9, 2023

by Sarah M. Raben | Jun 12, 2023 | IRS Guidance, Tax Reform, Tax Refunds

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 5, 2023 – June 9, 2023.

June 5, 2023: The IRS released Internal Revenue Bulletin 2023-23, which highlights the following:

Revenue Ruling 2023-11: This revenue ruling establishes that the following interest rates will remain the same for the calendar quarter beginning July 1, 2023:
- Overpayments: 7%
- Overpayments for corporations: 6%
- Corporate overpayments for portions exceeding $10,000: 4.5%
- Underpayments: 7%
- Large corporate underpayments: 9%

Notice 2023-41: This notice provides the applicable reference price for qualified natural gas production from qualified marginal wells during taxable years beginning in calendar year 2022 for the purpose of determining the marginal well production credit under Section 45I.

REG-108054-21: These proposed regulations provide guidance on the application of the transfer for valuable consideration rules under Section 101 and associated information reporting requirements for reportable policy sales of interests in life insurance contracts under Section 6050Y. The proposed regulations would amend the rules for exchanges of life insurance contracts qualifying for nonrecognition of gain or loss, as well as for certain acquisitions of interests in life insurance contracts in transactions that qualify as corporate reorganizations.

Revenue Ruling 2023-10: This revenue ruling provides the applicable federal rates for federal income tax purposes for June 2023. The short-term federal interest rate is 4.43%, the mid-term rate will drop to 3.56% and the long-term rate is 3.79%.

June 6, 2023: The IRS released Tax Tip 2023-76, providing business taxpayers with tips for income tax deductions before they travel on work trips.

June 7, 2023: The IRS issued a statement reassuring California taxpayers covered by disaster declarations that they’ll continue to have an automatic extension to file and pay taxes. The IRS is legally required to send a Notice CP14 to taxpayers with a balance due. While the notice says they need to pay in 21 days, California taxpayers under the disaster declaration have until later this year to pay.

June 7, 2023: The IRS released Tax Tip 2023-77, reminding tax professionals to register for the 2023 IRS Nationwide Tax Forums. Early registration expires June 15. See additional information below under Upcoming Events.

June 7, 2023: The IRS announced it was granting penalty relief for corporations that did not pay estimated tax related to the new corporate alternative minimum tax (CAMT). Notice 2023-42 provides that the IRS will waive the penalty for failure to pay estimated income tax for a taxable year that begins after December 31, 2022, and before January 1, 2024, because of the challenges associated with determining the amount of a corporation’s CAMT liability and whether a corporation is subject to the CAMT.

June 7, 2023: The IRS reminded taxpayers of the 2023 mid-June [...]

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Weekly IRS Roundup January 17 – January 20, 2023

by McDermott Will & Emery | Jan 23, 2023 | IRS Guidance, Tax Reform, Tax Refunds

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 17, 2023 – January 20, 2023.

January 17, 2023: The IRS released Internal Revenue Bulletin 2023-3, which highlights the following:

Notice 2023-10: This notice provides that calendar year 2022 will be a transition period for purposes of implementing the $600 reporting threshold for third-party settlement organizations. As a result, third-party organizations will not be required to report tax year 2022 transactions on Form 1099-K to the IRS or the payee for the lower $600 threshold amount unless the amount exceeds $20,000 and the number of transactions exceeds 200.

Notice 2023-2: This notice provides interim guidance on the new 1% excise tax on a covered corporation’s repurchases of corporate stock under Section 4501. Section 4501 was added as part of the Inflation Reduction Act of 2022 (IRA). The notice provides an exclusive list of Section 317(b) redemption transactions that are treated as Section 317(b) redemption but are not repurchases, as well as an exclusive list of economically similar transactions. The notice applies to stock repurchases and issuances of stock made after December 31, 2022.

Announcement 2023-1: This announcement notifies taxpayers of the applicable reference standard that must be used to determine the amount of the energy-efficient commercial building property deduction allowed under Section 179D, as amended by the IRA. This announcement identifies the existing reference standard, affirms a new one and clarifies when the two reference standards will apply.

Notice 2023-1: This notice informs taxpayers that the IRS and the US Department of the Treasury (Treasury) intend to propose new clean vehicle credit regulations, addressing the definitions of certain terms in Section 30D.

Notice 2023-03: This notice provides the 2023 optional standard mileage rates used to calculate the deductible costs of operating an automobile for business, charitable, medical or moving purposes. As of January 1, 2023, the standard mileage rates for the use of a car, van, pickup or panel truck are:
- 5 cents per mile driven for business use
- 22 cents per mile driven for medical or moving purposes for qualified active-duty members of the armed forces
- 14 cents per mile driven in service of charitable organizations

Notice 2023-7: This notice announces that the IRS and the Treasury plan to issue guidance on the new corporate alternative minimum tax (CAMT), which imposes a 15% minimum tax on the adjusted financial statement income of large corporations for taxable years beginning after December 31, 2022. It also clarifies which corporations the CAMT applies to and how the alternative minimum tax is calculated.

Notice 2023-9: This notice informs taxpayers that the Treasury and the IRS have reviewed the incremental cost for all street vehicles in calendar year 2023 and the analysis shows [...]

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Weekly IRS Roundup December 26 – December 30, 2022

by McDermott Will & Emery | Jan 3, 2023 | IRS Guidance, Tax Reform

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 26, 2022 – December 30, 2022.

December 26, 2022: The IRS released Internal Revenue Bulletin 2022-52, which highlights the following:

Proposed Regulations 106134-22: These proposed regulations identify certain syndicated conservation easement (SCE) transactions and substantially similar transactions as “listed transactions,” which means they must be reported to the IRS.

Revenue Procedure 2022-43: This procedure sets out the final qualified intermediary withholding agreement (QI agreement), which began on January 1, 2023. The QI agreement allows certain people to enter into an agreement with the IRS to simplify their obligations as withholding agents and as payors for amounts paid to their account holders and allows certain people to act as qualified derivatives dealers and assume primary withholding and reporting responsibilities on all dividend equivalent payments they make.

Announcement 2022-28: This announcement is released in conjunction with the above proposed regulations that identify certain SCE transactions as “listed transactions.” The announcement explains that the regulations are being proposed in response to certain court decisions holding that the Administrative Procedure Act requires the IRS to identify listed transactions through notice-and-comment rulemaking and that the IRS plans to issue additional regulations related to other “listed transactions.”

Notice 2022-61: This notice provides guidance on the prevailing wage and apprenticeship requirements, as amended by the Inflation Reduction Act of 2022 (IRA). This notice also serves as the published guidance establishing the 60-day period with respect to the applicability of the prevailing wage and apprenticeship requirements.

Proposed Regulations 113839-22: This document contains proposed regulations that treat members of a consolidated group as a single US shareholder in certain cases for purposes of Section 951(a)(2)(B). The proposed regulations affect consolidated groups that own stock of foreign corporations.

Revenue Procedure 2022-42: This procedure provides guidance on new rules added as part of the IRA on how to enter into a written agreement with the IRS to provide periodic written reports containing specified information related to a clean vehicle manufactured. It also provides the procedures for people selling vehicles to report information to the IRS in order for the vehicle to be eligible for the credit.

December 27, 2022: The IRS and the US Department of the Treasury (Treasury) announced interim guidance on the corporate stock repurchase excise tax. Notice 2023-2 provides the interim guidance on the new 1% excise tax on a covered corporation’s repurchases of corporate stock under Section 4501. (Section 4501 was added as part of the IRA.) The notice provides an exclusive list of Section 317(b) redemption transactions that are treated as Section 317(b) redemption but are not repurchases, as well as an exclusive list of transitions that are economically similar transactions. The notice applies to stock [...]

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