The IRS and the Treasury Department on Friday released Notice 2024-10, which provides additional interim guidance on the new corporate alternative minimum tax.
The corporate AMT was created by last year’s Inflation Reduction Act and imposes a 15% minimum tax on the adjusted financial statement income (AFSI) of large corporations for taxable years beginning after Dec. 31, 2022. The corporate AMT generally applies to large corporations with average annual financial statement income exceeding $1 billion.
The IRS previously issued Notice 2023-64 last September, guidance aimed at helping corporations determine whether the new corporate AMT applies to them and how to compute the new tax. The guidance issued in September clarifies and supplements Notice 2023-07 and Notice 2023-20 issued earlier this year. Treasury and IRS anticipate that forthcoming proposed regulations will be consistent with this interim guidance.
The new guidance released on Dec. 15 provides rules for determining the AFSI of a U.S. shareholder when a controlled foreign corporation (CFC) pays a dividend to the U.S. shareholder or another CFC.
The guidance also modifies and clarifies the rules in Notice 2023-64 for determining the applicable financial statement of a corporation that is included in a consolidated tax return.
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