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Helen Y. Huang

Associate

[email protected]

+1.212.692.6799

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Helen advises clients on a broad range of tax issues related to transactions, IPOs, and corporate structures and provides guidance on US and international tax rules applicable to multinationals. She advises clients in a variety of industries, including financial services.

Prior to joining Mintz, Helen was a senior associate focused on M&A international tax at a Big Four accounting firm. In that role, she advised private equity funds and their portfolio companies on tax matters pertaining to cross-border M&A transactions, IPO structures, debt financing transactions, leverage distributions, and other corporate structures. She also designed tax-efficient structures involving international indirect and direct transfer rules. In addition, Helen has experience performing tax due diligence on target companies and preparing tax models to identify tax benefits, tax exposures, and potential cost savings.

While earning her JD, Helen worked as a law clerk for a Boston-based law firm, where she assisted with the drafting of disclosure provisions, arbitration clauses, and bylaws for corporations. She also had an internship and an externship for global investment management companies. In law school, she served as associate executive editor of the Suffolk Journal of Trial & Appellate Advocacy. Additionally, she received an Honorable Mention Brief Award and an Honorable Mention Oral Advocate Award.

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Proposed Treasury Regulations Provide Guidance on Stock Buyback Excise Tax for Redemptions and M&A Transactions

May 23, 2024 | Alert | By David Salamon, Gregg M. Benson, Timothy J. Santoli, Helen Huang

Read about proposed Treasury regulations that provide guidance on the application of the stock buyback excise tax to redemptions and M&A transactions.

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This past summer, the Treasury and Internal Revenue Service (IRS) published proposed Treasury Regulations (88 FR 40528 and 88 FR 40496) under two key provisions of the Inflation Reduction Act of 2022 (IRA) designed to enable taxpayers and tax-exempt entities to monetize certain energy-related federal tax credits. Section 6417  allows certain tax-exempt and governmental entities that historically could not benefit from such tax credits to receive direct payments from the government in lieu of such tax credits. Section 6418 permits taxpayers to transfer all or a portion of certain energy-related tax credits to unrelated parties for cash. By broadening the universe of organizations that are able to make use of energy-related tax credits through the direct pay provisions and creating a more direct pathway for taxpayers interested in financing energy projects to share credits through transferability, these provisions stand to significantly expand the market for investment in energy projects.

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