The American Institute of CPAs (AICPA) is urging the Department of Treasury and the Internal Revenue Service (IRS) to provide additional clarity and simplification regarding three recent Corporate Alternative Minimum Tax (CAMT) notices. The group’s letter includes comments on Notices 2025-46, 2025-49, 2026-7 and the issues within these notices that have not been addressed.
The AICPA letter is intended to reduce compliance burdens, prevent double counting of income, improve consistency between financial and tax reporting, and make the CAMT rules more administrable for taxpayers and tax professionals. The recommendations focus on purchase accounting and push-down accounting, domestic research and experimental (R&E) expenditures under section 174A, intangible drilling cost and the Controlled Foreign Corporations (CFC) double counting issue.
The letter requests guidance and offers recommendations in the following areas:
- Withdraw the purchase accounting, push down accounting adjustment rules and the corresponding interim rule in Section 3.04(3) of Noaice 2025-46to better align CAMT with its statutory intent and reduce significant taxpayer compliance burdens. These adjustment rules require taxpayers to reverse purchase accounting and push-down accounting adjustments for CAMT purposes.
- Provide guidance under section 56A(c)(15) and section 56A(e) coordinating applicable financial statement income (AFSI) with domestic R&E expenditures under section 174A. The AICPA’s letter requests guidance coordinating AFSI with section 174A domestic R&E expenditures by recommending a targeted adjustment allowing tax recovery to be reflected in AFSI when book recovery is slower, while preventing double deductions.
- Allow a common parent (or other designated agent) of a CAMT tax consolidated group to file a single Form 4626, computing CAMT on a tax consolidated group basis. That CAMT liability and related attributes should then be allocated between the separate regular tax consolidated return groups using an administrable method. Additional guidance is needed for both administrability and to avoid disputes between taxpayers and the government.
- Provide additional guidance clarifying the adjustment under section 56A(c)(13), as amended by the OBBBA. Specifically, the AICPA’s letter requests guidance to assist taxpayers with determining the amount of “depletion expense that is taken into account on the taxpayer’s applicable financial statement (AFS) with respect to the intangible drilling and development costs of such property” (AFS depletion).
- State that taxpayers are not required to early adopt multiple disparate provisions in order to obtain relief for the CFC double counting issue. The letter asks that until the final regulations are issued, taxpayers be allowed to rely on Notice 2024-10, interim CAMT guidance.
“The AICPA’s recommendations focus on reducing unnecessary complexity, improving administrability and aligning the CAMT framework with its statutory intent and policy objectives,” says Reema Patel, Senior Manager, AICPA Tax Policy & Advocacy. “The clarity of the CAMT matters not only to affected companies and their advisors, but also to investors and the broader economy, influencing business decisions, investment plannings and financial reporting.”
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