US: proposed regulations on Corporate Alternative Minimum Tax
On 12 September 2024 the US Treasury Department and IRS released REG-112129-23 (proposed regulations) on the Corporate Alternative Minimum Tax (CAMT) created by the Inflation Reduction Act 2022. As a reminder CAMT generally imposes a 15% minimum tax on the adjusted financial statement income (AFSI) of ‘applicable corporations’: those who are part of groups whose three-year average annual AFSI exceeds $1bn.
A comprehensive analysis of the proposed regulations is outside the scope of this article. However readers should be aware that this latest tranche of CAMT guidance does little to alleviate taxpayer concerns about the complexity of the regime. Multiple provisions in the proposed regulations cause enormous administrative and compliance burdens lend themselves to varied interpretations and leave many issues unclear. Furthermore a number of the rules could increase the number of applicable corporations or increase perhaps materially an existing...
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US: proposed regulations on Corporate Alternative Minimum Tax
On 12 September 2024 the US Treasury Department and IRS released REG-112129-23 (proposed regulations) on the Corporate Alternative Minimum Tax (CAMT) created by the Inflation Reduction Act 2022. As a reminder CAMT generally imposes a 15% minimum tax on the adjusted financial statement income (AFSI) of ‘applicable corporations’: those who are part of groups whose three-year average annual AFSI exceeds $1bn.
A comprehensive analysis of the proposed regulations is outside the scope of this article. However readers should be aware that this latest tranche of CAMT guidance does little to alleviate taxpayer concerns about the complexity of the regime. Multiple provisions in the proposed regulations cause enormous administrative and compliance burdens lend themselves to varied interpretations and leave many issues unclear. Furthermore a number of the rules could increase the number of applicable corporations or increase perhaps materially an existing...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
