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Corporate alternative minimum tax: what the proposed regulations could mean for companies
October 2, 2024 @ 1:00 pm – 2:30 pm EDT
Free
1.8 CPE credits
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
