News & Analysis as of September 19, 2024

Alternative Minimum Tax › Corporate Taxes

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The Alternative Minimum Tax is an aspect of the United States federal tax code that seeks to capture a minimum level of revenue from all taxpayers and to ensure that some earners are not escaping tax liability through certain tax breaks or deductions. Liability under the AMT is calculated by adding certain deductions back into an individual's adjusted gross income, subtracting the AMT exemption and then, paying a percentage of the remaining figure. less -

Navigating the New Corporate Alternative Minimum Tax: Strategic Asset Allocation and Its Impact on M&A

Ankura on 4/3/2024

The new corporate alternative minimum tax (CAMT) creates incentives for large companies to allocate more value to amortizing intangible assets and less value to assets like goodwill that do not amortize for book purposes. ...more

Insight Into Hedge Accounting Elections & Corporate Alternative Minimum Tax Considerations

Opportune LLP on 11/17/2023

The Inflation Reduction Act (IRA) of 2022 significantly changed the U.S. Federal income tax code, including introducing the new Corporate Alternative Minimum Tax (CAMT). The CAMT is a parallel tax system that applies to...more

CAMT round three: The IRS and Treasury release third round of substantive CAMT guidance

Eversheds Sutherland (US) LLP on 9/22/2023

On September 12, 2023, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released a third substantive piece of guidance, Notice 2023-64 (Notice) clarifying the application of the new corporate...more

Relief from the heat: IRS provides penalty waiver for taxpayers not considering CAMT liability in 2023 estimated tax payments

Eversheds Sutherland (US) LLP on 6/8/2023

On June 7, 2023, the IRS released Notice 2023-42 (the Notice), providing taxpayers relief from the addition to tax under Section 6655 in connection with the application of the new corporate alternative minimum tax (CAMT). In...more

Charting a course: Guidance issued to help navigate potential issues for insurance industry with the corporate alternative minimum...

Eversheds Sutherland (US) LLP on 3/8/2023

On February 17, 2023, the Department of Treasury (Treasury) and the Internal Revenue Service (the IRS) issued Notice 2023-20 (the Notice), to provide guidance that is intended to help avoid unintended adverse consequences to...more

U.S. Tax Laws: A Review of 2022 and a Look Ahead to 2023

Davies Ward Phillips & Vineberg LLP on 2/22/2023

As we settle into the new year, let’s take a moment to first consider last year’s tax developments and then take a look ahead to what 2023 might have in store for us. Review of U.S. Tax Developments in 2022- In 2022 we...more

Notice 2023-7 Provides Initial Guidance Regarding the Corporate Alternative Minimum Tax

Cadwalader, Wickersham & Taft LLP on 1/31/2023

On December 27, 2022, Treasury issued Notice 2023-7, which provides guidance regarding the new Corporate Alternative Minimum Tax (“CAMT”) that taxpayers can rely on until Treasury publishes additional guidance. As mentioned...more

Notice 2023-7: First Peek at Corporate AMT Guidance

Holland & Knight LLP on 1/11/2023

As promised, the U.S. Department of the Treasury (Treasury Department) and IRS on Dec. 27, 2022, issued guidance regarding the new corporate alternative minimum tax (CAMT) enacted as part of the Inflation Reduction Act (IRA)....more

[Hybrid Event] The New Corporate AMT and Attorney/Client Privilege: Why Your Attorney Should Hire Your Accountant - January 12th,...

Vinson & Elkins LLP on 12/29/2022

The new corporate alternative minimum tax (“CAMT”) generally applies to corporations with 3-year average “book” income in excess of $1 billion. Thus whether a corporation owes CAMT may depend on positions taken under GAAP....more

President Biden Signs the Inflation Reduction Act into Law

Akerman LLP on 9/2/2022

On August 16, 2022, President Joe Biden signed the Inflation Reduction Act of 2022 (H.R. 5376) (the IRA) into law. The key provisions that may affect the private equity sector and corporations include...more

US Inflation Reduction Act – Corporate Minimum Tax and Stock Repurchase Excise Tax

Mayer Brown Free Writings + Perspectives on 9/1/2022

If you thought the recent price increase at your neighborhood store was inflation’s last flop, think again. The Inflation Reduction Act (“IRA”), which was signed into law by President Biden on August 16, 2022, is estimated to...more

Inflation Reduction Act of 2022: Corporate Alternative Minimum Tax, Excise Tax on Corporate Stock Repurchases, and Business Loss...

Dechert LLP on 8/26/2022

On August 12, 2022, the U.S. Congress passed the Inflation Reduction Act of 2022 (the “Act”), which was signed into law by President Biden on August 16, 2022. Alongside sweeping changes to energy, environmental and...more

Analysis: Impact of Inflation Reduction Act’s Stock Buyback Excise Tax and Corporate Minimum Tax

Latham & Watkins LLP on 8/22/2022

Beginning in 2023, an excise tax of 1% will apply to public company stock buybacks and a 15% corporate minimum tax generally will apply to corporations with book income exceeding $1 billion. Key Points: ..Public...more

Signed, sealed, delivered: Biden signs Inflation Reduction Act enacting “new” corporate minimum tax

Eversheds Sutherland (US) LLP on 8/18/2022

On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the most notable IRA provisions is a 15% corporate alternative minimum tax on corporations with book profits...more

Inflation Reduction Act Creates New Corporate Minimum Tax

Morgan Lewis on 8/17/2022

The Inflation Reduction Act of 2022, signed by US President Joseph Biden on August 16, 2022, includes a new alternative minimum tax for corporations with profits of more than $1 billion....more

Inflation Reduction Act Tax Implications

Lowenstein Sandler LLP on 8/17/2022

The President is expected to imminently sign the Inflation Reduction Act of 2022 (the “Act”), which was passed by both the Senate and House of Representatives. This Client Alert addresses two main tax provisions in the...more

The Inflation Reduction Act: A Tax Overview

Miller Canfield on 8/16/2022

The Inflation Reduction Act of 2022 (the “Act”), which passed both chambers of Congress on Aug. 12, 2022, includes the following tax provisions meant to raise government revenues and subsidize green energy initiatives....more

U.S. Senate Passes Inflation Reduction Act

Paul Hastings LLP on 8/11/2022

On August 7, after weeks of negotiations, the Senate voted 51-50 to pass a budget reconciliation package known as the Inflation Reduction Act (the “Bill”), introduced by Senators Joe Manchin (D‑WV) and Chuck Schumer (D‑NY) in...more

Senator Manchin Announces That He Will Not Support the Build Back Better Act – Where Things Stand Now

Proskauer - Tax Talks on 12/20/2021

Yesterday, on December 19, 2021, Senator Joe Manchin (D., W.Va.) said that he opposes the Build Back Better Act, which effectively prevents its passage. While there are no immediate prospects for the Build Back Better Act to...more

US House Rules Committee Modifies the “Build Back Better Act”

Mayer Brown on 11/12/2021

In less than a week, the Rules Committee of the US House of Representatives (the “Rules Committee”) released two versions of modified legislative text of H.R. 5376, the Build Back Better Act. The first version was released on...more

Revised U.S. Tax Proposals Will Affect Foreign Investment

Davies Ward Phillips & Vineberg LLP on 11/9/2021

The U.S. House Committee on Rules recently released an updated version of the Build Back Better Act (Act) to reflect the White House’s Build Back Better framework (Framework) announced on the same day (October 28, 2021). ...more

New York Is Poised For Some Significant Tax Increases

Rivkin Radler LLP on 3/30/2021

Are the rich making enough of a contribution to society? Are they bearing their fair share of taxes? Many New York legislators don’t think so. Following the elections of November 2020, the State’s Democratic party secured...more

A Closer Look at Biden’s Tax Proposals

Skadden, Arps, Slate, Meagher & Flom LLP on 9/24/2020

Former Vice President Joseph Biden has proposed a number of fundamental changes to the tax code over the course of his campaign. If he is elected president and if the Democrats keep control of the House of Representatives and...more

Tax Relief to Help Weather the Storm of COVID-19

Jaburg Wilk on 4/29/2020

As the COVID-19 pandemic has wreaked havoc on our personal, financial and business lives, the government has responded with legislative and administrative relief. This is a high-level summary of some of the enacted measures...more

IRS Issues Guidance Regarding Net Operating Loss Carryback Waivers and Refunds Under the CARES Act | Blogs | Coronavirus Resource...

Foley & Lardner LLP on 4/16/2020

On April 9, 2020, the IRS issued: Rev. Proc. 2020-24, which provides guidance under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) relating to relinquishment of certain net operating loss (NOL)...more

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Alternative Minimum Tax › Corporate Taxes

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