Andersen Managing Director Joe Calianno's comments are featured in the recent Tax Notes article, IRS Stands by Express Delegation in Stock Buyback Rules. The article discusses the stock buyback excise tax funding rule, under which the excise tax applies if an applicable specified affiliate of a foreign publicly traded corporation funds "by any means" a redemption or acquisition of the foreign corporation's stock with the principal purpose of avoiding the excise tax. Business groups have recently argued that the rule impermissibly extends beyond the scope of the statute (Sec. 4501) it is implementing. Joe said that the breadth of the rule could potentially implicate many ordinary business transactions, such as a foreign parent with an existing stock repurchase program in place. He also said that it was unclear whose purpose is to be considered when determining if a principal purpose exists.