Weil Tax BLOG - Feed https://tax.weil.com/contributor/madeline-joerg/ Views and developments from the Tax Department at Weil Fri, 22 May 2026 16:18:43 +0000 hourly 1 New IRS Proposed Regulations Address Dual Consolidated Loss Rules https://tax.weil.com/features/new-irs-proposed-regulations-address-dual-consolidated-loss-rules/ Thu, 08 Aug 2024 20:34:12 +0000 Devon Bodoh Madeline Joerg Sydnei Jones https://tax.weil.com/?p=2286 On August 6, 2024, the Treasury Department (“Treasury”) issued Proposed Regulations (REG- 102144-04) (the “Proposed Regulations”) regarding section 1503(d) of the Internal Revenue Code. Specifically, the Proposed Regulations clarify the application of the existing dual consolidated loss (“DCL”) rules by providing guidance regarding: (i) the interplay of the DCL rules with the intercompany transaction regulations

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]]> Updated Procedures for Section 355 Private Letter Rulings: Rev. Proc. 2024-24 and Notice 2024-38 https://tax.weil.com/features/updated-procedures-for-section-355-private-letter-rulings-rev-proc-2024-24-and-notice-2024-38/ Mon, 13 May 2024 14:03:43 +0000 Joseph Pari Devon Bodoh Graham Magill Blake Bitter Madeline Joerg Grant Solomon Adam Sternberg https://tax.weil.com/?p=2198 On May 1, 2024, the Treasury Department and Internal Revenue Service (the “Treasury” and “IRS,” respectively) issued Revenue Procedure (“Rev. Proc.”) 2024-24 and Notice 2024-38 (collectively, the “Guidance”). The Rev. Proc. provides procedures for requesting private letter rulings from the IRS relating to certain matters pertaining to transactions intended to qualify under Section 355 and

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]]> Notice 2023-2: Proposed Guidance on the Stock Buyback Excise Tax https://tax.weil.com/insights/notice-2023-2-proposed-guidance-on-the-stock-buyback-excise-tax/ Thu, 29 Dec 2022 14:37:08 +0000 Devon Bodoh Joseph Pari Madeline Joerg Grant Solomon https://tax.weil.com/?p=1810 The Inflation Reduction Act of 2022 imposes a one percent excise tax (the “Excise Tax”) on the repurchase of corporate stock under Section 4501 of the Internal Revenue Code (“Section 4501” and the “Code”, respectively[1]) by a publicly traded U.S. corporation (a “covered corporation”) beginning after December 31, 2022. For purposes of the Excise Tax,

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]]> The Inflation Reduction Act of 2022 imposes a one percent excise tax (the “Excise Tax”) on the repurchase of corporate stock under Section 4501 of the Internal Revenue Code (“Section 4501” and the “Code”, respectively[1]) by a publicly traded U.S. corporation (a “covered corporation”) beginning after December 31, 2022. For purposes of the Excise Tax,

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