CAMT Series Part 1: What Are the Basic Rules for Calculation?

On September 12, 2024, Treasury and the IRS released proposed regulations (REG–112129–23) on the corporate alternative minimum tax (“CAMT”) under §56A, §59, and §1502 (the “Proposed Regulations”). This article, the first in a series, provides an overview of the core concepts and mechanics involved, and subsequent articles will delve deeper into the details, including with respect to certain international provisions and considerations for foreign-parented multinational groups (“FPMGs”).

The Proposed Regulations are extensive, and contain hundreds of pages of guidance – some of which is consistent with prior CAMT Notices, while ...