The CAMT imposes a 15-percent minimum tax on adjusted financial statement income of large corporations for taxable years beginning after Dec. 31, 202 and generally applies to corporation with an aver annual AFSI of more than $1 billion.

The proposed regulations provide definitions and general rules for determining and identifying AFSI and also include rules regarding various statutory and regulatory adjustments in determining AFSI; determining if a corporation is subject to the CAMT, including rules for members of a foreign parented multinational group  and the determination of the CAMT foreign tax credit.

The proposals also address the application of CAMT to affiliated corporations filing a consolidated income tax return.

Previously the IRS issued Notice 2023-07, Notice 2023-20, Notice 2023-64 and Notice 2024-10, to provide interim guidance on the CAMT. The proposed regulations issued today include rules incorporating this interim guidance.

Furthermore, the IRS today issued Notice 2024-66 PDF, which waives the penalty for a corporation’s failure to pay estimated tax with respect to its CAMT for a taxable year that begins after Dec. 31, 2023, and before Jan. 1, 2025.

Bob Scott

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Bob Scott has provided information to the tax and accounting community since 1991, first as technology editor of Accounting Today, and from 1997 through 2009 as editor of its sister publication, Accounting Technology. He is known throughout the industry for his depth of knowledge and for his high journalistic standards.  Scott has made frequent appearances as a speaker, moderator and panelist and events serving tax and accounting professionals. He  has a strong background in computer journalism as an editor with two former trade publications, Computer+Software News and MIS Week and spent several years with weekly and daily newspapers in Morris County New Jersey prior to that.  A graduate of Indiana University with a degree in journalism, Bob is a native of Madison, Ind