News & Analysis as of

Alternative Minimum Tax › Inflation Reduction Act (IRA)

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... more +
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 -
Vinson & Elkins LLP

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

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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

Vinson & Elkins LLP

CAMT and Partnerships: A Taxing Relationship Explained

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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

Vinson & Elkins LLP

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

Vinson & Elkins LLP on

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

Vinson & Elkins LLP

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

Vinson & Elkins LLP on

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

Eversheds Sutherland (US) LLP

Be careful what you wish for: IRS and Treasury release goliath CAMT NPRM full of nuance and complexity

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On September 12, 2024, the Internal Revenue Service and Department of the Treasury (collectively, the Government) issued long-awaited proposed regulations (the NPRM), providing guidance regarding application of the corporate...more

Vinson & Elkins LLP

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

Vinson & Elkins LLP on

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

Opportune LLP

Insight Into Hedge Accounting Elections & Corporate Alternative Minimum Tax Considerations

Opportune LLP on

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

Davies Ward Phillips & Vineberg LLP

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

Davies Ward Phillips & Vineberg LLP on

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

Holland & Knight LLP

Notice 2023-7: First Peek at Corporate AMT Guidance

Holland & Knight LLP on

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

Eversheds Sutherland (US) LLP

Treasury announces limited IRA tax guidance to ring in the new year

Eversheds Sutherland (US) LLP on

On December 19, 2022, Treasury announced a timeline for releasing information on certain tax provisions of the Inflation Reduction Act (IRA). As set forth in the announcement, Treasury will provide the following information...more

White and Williams LLP

Inflation Reduction Act

White and Williams LLP on

On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (“IRA”) into law. While much of the legislation is geared towards climate change mitigation, clean energy, and provisions to promote health care...more

Akerman LLP

President Biden Signs the Inflation Reduction Act into Law

Akerman LLP on

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

Vinson & Elkins LLP

New Climate Law Overhauls US Tax Code With Benefits, Flexibility

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The Inflation Reduction Act of 2022 (IRA) represents one of the most sweeping pieces of climate policy legislation ever enacted in the United States. While the final impact of the IRA remains to be seen, we expect there will...more

Mayer Brown Free Writings + Perspectives

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

Mayer Brown Free Writings + Perspectives on

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

Fox Rothschild LLP

Overview of Some Changes in the Inflation Reduction Act of 2022

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President Joe Biden signed the Inflation Reduction Act of 2022 (the “IRA”) into law on Aug. 16, 2022, resulting in significant changes to the Internal Revenue Code. An overview of a few of the changes is below....more

Husch Blackwell LLP

The Inflation Reduction Act of 2022: An Overview

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On August 16, 2022, President Joseph Biden signed into law the Inflation Reduction Act of 2022 (IRA). The IRA is substantially a reworking and repackaging of prior legislative efforts—principally the proposed Build Back...more

Dechert LLP

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

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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

Levenfeld Pearlstein, LLC

Tax Changes in Inflation Reduction Act

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On August 7, 2022, the Senate passed the Inflation Reduction Act of 2022. The legislation passed the House on August 12, and was signed by President Biden on August 16. Among significant changes designed to fight climate...more

Vinson & Elkins LLP

Inflation Reduction Act of 2022: Corporate Alternative Minimum Tax

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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

Fenwick & West LLP

The New Corporate AMT: Impact on International Operations

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Introduction On August 16, President Biden signed into law the Inflation Reduction Act of 2022, P.L. 117-169 (IRA). The law addresses a range of issues, from climate change to energy security to prescription drug prices for...more

Latham & Watkins LLP

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

Latham & Watkins LLP on

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

Harris Beach Murtha PLLC

Key Tax Provisions of the Inflation Reduction Act of 2022

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On August 16, 2022, President Joe Biden signed the Inflation Reduction Act of 2022 (the “Act”) into law. Among its provisions, the Act provides the biggest investment ever in the US to fight climate change, places a cap on...more

Eversheds Sutherland (US) LLP

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

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​​​​​​​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

Morgan Lewis

Inflation Reduction Act Creates New Corporate Minimum Tax

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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

Lowenstein Sandler LLP

Inflation Reduction Act Tax Implications

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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

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