Following the release of interim guidance (Notice 2023-7) by the US Department of the Treasury and the Internal Revenue Service (IRS) addressing how the Corporate Alternative Minimum Tax (CAMT) applies to corporations, certain partnerships, troubled companies and affiliated groups of corporations that file consolidated tax returns, the American Institute of CPAs (AICPA) submitted comments and recommendations which identify and provide additional information regarding CAMT guidance provided in the Notice and for rules not included in the Notice.
The interim rules provided by Treasury and the IRS also address determining CAMT adjustments for depreciation and the treatment of federal income tax credits, as well as providing a safe-harbor method for determining whether a corporation is an applicable corporation subject to CAMT.
The AICPA submitted comments and recommendations on the following issues:
1. Financial Reporting and Accounting for Income Taxes
2. Passthrough Issues
3. General Concepts and Methods & Periods
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4. Mergers & Acquisitions Issues
AICPA senior manager for tax policy & advocacy, Reema Patel, said: “The interim guidance released by Treasury and the IRS spotlights certain areas that should be addressed before the proposed regulations are released.
“The AICPA’s recommendations and comments focus on four main issues that require some level of specificity and clarity in order to ensure tax compliance,” she continued.
Previously, the AICPA submitted two letters to Congressional tax-writing committee leadership highlighting key issues with the corporate profits minimum tax, as well as a letter to Treasury and the IRS in October of 2022 requesting immediate guidance on the CAMT rules.