Andersen Managing Director Joe Calianno’s comments are featured in the recent Tax Notes article, Final Buyback Regs Are Good News for M&A Transactions Too. The article notes that the final version of the regulations implementing the 1% excise tax on stock buybacks does not include the so-called funding rule. The rule would have included within the scope of the tax certain purchases of foreign parent stock funded “by any means, directly or indirectly” by a U.S. subsidiary if avoidance of the tax were found to be a principal purpose of the funding. Joe said he was not surprised that the funding rule was not included in the final regulations because they were controversial and widely criticized by the tax community as being burdensome, lacking clarity, and being overly broad.