IRS clarifies rules for corporate alternative minimum tax

6 months ago 359

IR-2023-241, Dec. 15, 2023

WASHINGTON — The Department of Treasury and the Internal Revenue Service today issued Notice 2024-10 to provide additional interim guidance on the new corporate alternative minimum tax (CAMT).

Previously, the IRS issued Notice 2023-64PDF, which clarifies and supplements Notice 2023-07PDF and Notice 2023-20PDF issued earlier this year. Treasury and IRS anticipate that forthcoming proposed regulations will be consistent with this interim guidance.

The Inflation Reduction Act created the CAMT, which imposes a 15% minimum tax on the adjusted financial statement income (AFSI) of large corporations for taxable years beginning after Dec. 31, 2022. The CAMT generally applies to large corporations with average annual financial statement income exceeding $1 billion.

Today's guidance provides rules for determining the AFSI of a U.S. Shareholder when a controlled foreign corporation (CFC) pays a dividend to the U.S. Shareholder or another CFC.

The guidance also modifies and clarifies the rules in Notice 2023-64 for determining the applicable financial statement of a corporation that is included in a consolidated tax return.

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