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New US interim CAMT guidance offers welcome relief from possible double-counting of CFC earnings in AFSI, but possible compliance burdens

20 December 2023

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Tax Alerts, Legislation & Policy, National/Federal Taxation, Legislation & Policy, BEPS 2.0

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United States

Notice 2024-10 provides highly anticipated guidance on the corporate alternative minimum tax (CAMT) impact of distributions from controlled foreign corporations (CFCs) to U.S. Shareholders and other CFCs.The Notice also modifies and clarifies the rules in Notice 2023-64 for determining the applicable financial statement (AFS) of a corporation that is included in a consolidated tax return.Taxpayers may rely on the interim guidance in Notice 2024-10 for distributions received on or before the date forthcoming proposed regulations are published, and for distributions received before January 1, 2024, regardless of when proposed regulations are issued.Similarly, taxpayers may rely on the interim guidance in...