ACC appreciates the opportunity to provide comments on Notice 2023-2 (the Notice) regarding section 4501, a one percent excise tax on repurchases of corporate stock (the Excise Tax), which was enacted as part of the Inflation Reduction Act. The Excise Tax applies to the fair market value of any stock repurchased by a U.S. corporation that is traded on a securities exchange. In the case of foreign-headquartered corporation, the Excise Tax applies to a purchase from third parties of foreign-parent stock by a U.S. corporation or partnership that is more than 50% owned, directly or indirectly, by such foreign parent.