John Lynch

John Lynch

Vinson & Elkins LLP

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CAMT Claus Is Staying In Town?

Lawmakers have been making their lists and checking them twice, and soon we will find out who’s been naughty or nice. However, taxpayers and their advisors wishing for a repeal of the corporate alternative minimum tax in 2025...more

12/19/2024  /  Alternative Minimum Tax , Corporate Taxes , Income Taxes , IRS , Proposed Regulation , Tax Advice , Tax Cuts and Jobs Act , U.S. Treasury

CAMT Touch This: Treatment of Tax Credits, Direct Pay, and Transferability under the Corporate Alternative Minimum Tax

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

11/15/2024  /  Alternative Minimum Tax , Corporate Taxes , Energy Projects , Inflation Reduction Act (IRA) , IRS , Proposed Regulation , Renewable Energy , Tax Credits , U.S. Treasury

CAMT and Partnerships: A Taxing Relationship Explained

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the corporate...more

11/6/2024  /  Alternative Minimum Tax , Inflation Reduction Act (IRA) , IRS , Partnerships , Reporting Requirements , U.S. Treasury

CAMT Count Me Twice: Determining CAMT AFSI in Mergers and Acquisitions

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

10/24/2024  /  Alternative Minimum Tax , Corporate Net Income , Corporate Taxes , Inflation Reduction Act (IRA) , IRS , Proposed Regulation , Regulatory Authority , U.S. Treasury

Why CAMT I Get Away From You: Losing Applicable Corporation Status Under the Corporate Alternative Minimum Tax

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

10/8/2024  /  Alternative Minimum Tax , Corporate Net Income , Corporate Taxes , Inflation Reduction Act (IRA) , IRS , Proposed Regulation , Regulatory Authority , U.S. Treasury

Treasury Releases Long-Awaited Proposed Regulations on the Corporate Alternative Minimum Tax

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

9/20/2024  /  Alternative Minimum Tax , Depreciation , Foreign Corporations , Foreign Tax , Inflation Reduction Act (IRA) , IRS , Proposed Regulation , Tax Credits , U.S. Treasury

Inflation Reduction Act of 2022: Corporate Alternative Minimum Tax

On August 16, 2022, the Inflation Reduction Act of 2022 (the “IRA”) was enacted into law. Among other changes to the Internal Revenue Code of 1986, as amended (the “Code”), the IRA imposes a 15% corporate alternative minimum...more

8/24/2022  /  Alternative Minimum Tax , Foreign Tax Credits , GAAP , Inflation Reduction Act (IRA) , Internal Revenue Code (IRC) , Master Limited Partnerships , Partnerships , Tax Credits , Taxable Income

Inflation Reduction Act of 2022: Excise Tax on Repurchases of Corporate Stock and Interesting Applications to SPACs

On August 16, 2022, the Inflation Reduction Act of 2022 (the “IRA”) was enacted into law. Among other changes to the Internal Revenue Code of 1986, as amended (the “Code”), the IRA imposes an excise tax on certain repurchases...more

8/23/2022  /  Excise Tax , Inflation Reduction Act (IRA) , Internal Revenue Code (IRC) , Share Buybacks , Special Purpose Acquisition Companies (SPACs)

Introducing The Up-SPAC Structure

As the pace of SPAC IPOs continues to set records, evolution of the economic terms has accelerated. We have seen changes to the warrant and promote structure (including “tontine” warrants), call rights motivating cashless...more

10/7/2020  /  Capital Raising , Financial Markets , Initial Public Offering (IPO) , Special Purpose Acquisition Companies (SPACs) , Voting Rights
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