The proposed US regulations on Corporate Alternative Minimum Tax, an important CJEU decision on state aid and the Irish Budget are among the recent developments reviewed by Tim Sarson (KPMG).
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...
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The proposed US regulations on Corporate Alternative Minimum Tax, an important CJEU decision on state aid and the Irish Budget are among the recent developments reviewed by Tim Sarson (KPMG).
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...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
