IRS Proposes Regulations for 15% Corporate Alternative Minimum Tax (CAMT)

The Internal Revenue Service (IRS) and the U.S. Department of the Treasury have recently unveiled proposed regulations that provide crucial guidance on the Corporate Alternative Minimum Tax (CAMT). This new tax provision, a key component of the Inflation Reduction Act, aims to ensure that large corporations pay their fair share of taxes. The CAMT imposes a 15% minimum tax on the adjusted financial statement income (AFSI) of qualifying corporations. Key Aspects of the Proposed Regulations 1. Scope and Applicability The CAMT targets large corporations with an average annual AFSI exceeding $1 billion . The regulations also include specific rules for members of foreign-parented multinational groups (FPMGs), ensuring that the tax is applied fairly across domestic and international corporate structures. 2. Calculation of AFSI The proposed regulations provide detailed guidance on determining AFSI, including: Definitions and general rules for...