IRS offers more guidance on corporate AMT

The Internal Revenue Service and the Treasury Department released a notice Friday providing additional guidance on the corporate alternative minimum tax for billion-dollar companies.

Last year’s Inflation Reduction Act created the CAMT, imposing a 15% minimum tax on the adjusted financial statement income of large corporations for taxable years starting after Dec. 31, 2022. The tax typically applies to big corporations with average annual financial statement income of over $1 billion.  

Notice 2024-10 includes rules for determining the annual financial statement income of a U.S. shareholder when a controlled foreign corporation pays a dividend to the shareholder or another controlled foreign corporation. 

It also modifies and clarifies the rules in a previous notice, Notice 2023-64, for determining the applicable financial statement of a corporation that is included in a consolidated tax return. Earlier this year, the IRS issued Notice 2023-64, which clarifies and supplements Notice 2023-07 and Notice 2023-20. The Treasury and the IRS expect their upcoming proposed regulations will be in line with this interim guidance.