The new corporate provision was included as part of the budget reconciliation negotiations.
The proposed 15% corporate alternative minimum tax (CAMT) based on book income would apply to companies that report over $1 billion in profits to shareholders. The CAMT is included as a primary revenue raiser in the latest version of the Build Back Better Act (BBBA), which was released October 28, 2021. The proposal would apply to tax years beginning after December 31, 2022.
15% minimum tax and Applicable Corporations
The proposal would establish a 15% minimum tax on a corporation's adjusted financial statement income to the extent it exceeds the corporate AMT foreign tax credit for the tax year (corporate AMT foreign tax credit discussed in the full text).
The 15% minimum tax would apply to any corporation (other than an S corporation, regulated investment company, or real estate investment trust) whose average annual adjusted financial statement income exceeds $1 billion over any consecutive three-tax-year period preceding the tax year.
The proposed CAMT would require taxpayers to perform two separate calculations for federal income tax purposes and pay the greater of the alternative minimum tax or their regular tax liability plus any base erosion and anti-abuse tax (BEAT) liability.