On April 9, 2024, the IRS and Department of the Treasury issued two Notices of Proposed Rulemaking providing further guidance on the application of Section 4501 of the Internal Revenue Code, which imposes a 1% excise tax on certain repurchases of corporate stock. The Proposed Regulations expand on and modify the initial guidance provided in Notice 2023-2 on December 27, 2022, including significantly narrowing the “funding” rule for repurchases of foreign corporate stock.