CAMT: new guidance and the fate of the existing proposed regulations

Insights from the EY Center for Tax Policy

Over the past few months, the Treasury Department has issued several notices regarding the application of the corporate alternative minimum tax (CAMT). The notices announce the Treasury Department’s intent to withdraw the existing proposed CAMT regulations (REG-112129-23) and issue new proposed CAMT regulations at a later date. The notices also: (1) provide new interim guidance on several issues that taxpayers can rely on until the new proposed CAMT regulations are issued, (2) delay the proposed applicability dates of forthcoming final CAMT regulations, and (3) provide more flexible options for relying on aspects of the existing proposed CAMT regulations prior to their withdrawal.

Join our team of Ernst & Young LLP subject matter professionals for a discussion of the technical aspects and potential implications of the interim guidance provided in Notice 2025-27, Notice 2025-28, Notice 2025-46, and Notice 2025-49, including:

• A new safe harbor for determining whether a corporation is an “applicable corporation”
• Adjusted financial statement income (AFSI) adjustments that result from ownership of a partnership interest and transactions involving partnerships
• AFSI adjustments that result from ownership of stock of a domestic corporation and transactions involving domestic corporations
• AFSI adjustments for troubled companies
• The determination of AFSI for a tax consolidated group
• The utilization of financial statement net operating losses
• New AFSI adjustments, including AFSI adjustments for certain unrealized gains and losses, industry specific AFSI adjustments, and AFSI adjustments for acquired goodwill
• Options for relying on the existing proposed CAMT regulations and the interim guidance in the notices

Panelists

• Tim Kerr, Partner, National Tax – International Tax and Transaction Services, Ernst & Young LLP
• Enrica Ma, Principal, National Tax – International Tax and Transaction Services, Ernst & Young LLP
• Chris Mayer-Dempsey, Principal, National Tax – Passthrough Transactions Group, Ernst & Young LLP
• Marie Milnes-Vasquez, Managing Director, National Tax – International Tax and Transaction Services, Ernst & Young LLP
• Brian Peabody, Principal, National Tax – International Tax and Transaction Services, Ernst & Young LLP
• Jeshua Wright, Partner, National Tax – International Tax and Transaction Services, Ernst & Young LLP

Moderator

• Tim Powell, Partner, National Tax – Accounting Periods, Methods & Credits, Ernst & Young LLP

EY webcast managed and produced by Ernst & Young LLP’s Tax Technical Knowledge Services Group, Washington, DC: Lynn Fairfax