On October 18, 2022, TEI submitted written comments to the U.S. Department of the Treasury and Internal Revenue Service regarding the Inflation Reduction Act’s new corporate alternative minimum tax (“CAMT”). TEI’s comments focused on the definition of applicable financial statement income and how it differs from taxable income under the Internal Revenue Code. Among the issues TEI commented upon were: (i) transition items from pre-CAMT years affecting post-CAMT years; (ii) relief from penalties and interest imposed on estimated tax payments; (iii) the need for guidance regarding how eliminations in consolidation when preparing financial statements will be treated under the CAMT; (iv) clarity for non-U.S. corporations that may be subject to the CAMT; and (v) the interaction of the CAMT with “fair value” accounting.
TEI’s comments were developed under the aegis of the Institute’s Tax Reform Task Force, whose chair is Jason Weinstein of Amazon.com.