Corporate alternative minimum tax: what the proposed regulations could mean for companies

In this webcast, panelists discuss the technical aspects and potential implications of the proposed CAMT regulations.

On September 12, 2024, the Treasury Department issued over 600 pages of long-awaited proposed regulations (REG-112129-23) on the application of the 15% corporate alternative minimum tax (CAMT) on the adjusted financial statement income (AFSI) of large corporations. The proposed regulations propose comprehensive rules for applying CAMT.

Join our team of Ernst & Young LLP subject matter professionals for a discussion of the technical aspects and potential implications of the proposed regulations, including:

• Whether a corporation is an “applicable corporation”
• An entity’s “applicable financial statement”
• AFSI basics and transition rules
• AFSI adjustments with respect to depreciable property
• An entity’s distributive share of AFSI with respect to a partnership investment
• AFSI adjustments resulting from contributions of property to partnerships and distributions of property by partnerships
• AFSI adjustments resulting from certain corporate transactions, including special rules that limit the use of acquired CAMT attributes
• The application of the CAMT to affiliated corporations filing a consolidated income tax return
• AFSI adjustments resulting from ownership of foreign corporation stock and transactions involving foreign corporations
• AFSI adjustments for controlled foreign corporations
• AFSI adjustments to prevent duplications and omissions
• The calculation of the CAMT foreign tax credit
• CAMT anti-abuse rules
• The applicability date of the proposed regulations, including early-reliance options

Panelists

• Enrica Ma, Principal, National Tax – International Tax and Transaction Services, Ernst & Young LLP
• Brian Peabody, Principal, National Tax – International Tax and Transaction Services, Ernst & Young LLP
• Chris Mayer-Dempsey, Senior Manager, National Tax – Passthrough Transactions Group, Ernst & Young LLP
• Rayth Myers, Senior Manager, National Tax – Accounting Periods, Methods & Credits, 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