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US proposed CAMT regulations offer some clarification, but AFSI adjustments are significantly complicated

01 October 2024

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Tax Alerts, Legislation & Policy, Compensation & Benefits, Banking & Capital Markets, Legislation & Policy, Global, BEPS 2.0

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United States

The recently proposed corporate alternative minimum tax (CAMT) regulations, issued on September 12, 2024, offer guidance for determining whether a corporation is an "applicable corporation" subject to the CAMT and computing an entity's adjusted financial statement income (AFSI). The AFSI computations, however, are significantly complicated. The proposed regulations also contain guidance on determining the CAMT foreign tax credit.The proposed regulations come more than two years after the CAMT was enacted as part of the Inflation Reduction Act (See Tax Alert 2022-1237), and after the issuance of multiple Treasury Department and IRS notices providing interim CAMT guidance (See Tax Alerts 2023-2105,...