The IRS has issued proposed regulations addressing the application of the Sec. 55 corporate alternative minimum tax (AMT).
The Inflation Reduction Act created the corporate AMT, which imposes a 15% minimum tax on the adjusted financial statement income (AFSI) of large corporations for taxable years beginning after Dec. 31, 2022.
The proposed regulations provide guidance on determining if a corporation is subject to the corporate AMT, including rules for members of a foreign-parented multinational group and the determination of the corporate AMT foreign tax credit.
The proposed regulations also address the application of the corporate AMT to affiliated corporations filing a consolidated income tax return. Learn more.