Interim guidance provided for the corporate alternative minimum tax

The IRS on Friday provided new interim guidance on the corporate alternative minimum tax (AMT) in Notice 2024-10 and said it expects that proposed regulations to be released in 2024 will be consistent with this guidance.

The interim guidance issued Friday provides rules for determining the adjusted financial statement income (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 a member of an affiliated group of corporations filing a consolidated return.

The corporate AMT, created by the Inflation Reduction Act of 2022, P.L. 117-169, imposes a 15% minimum tax based on the AFSI of corporations with AFSI over $1 billion, beginning after Dec. 31, 2022.

— To comment on this article or to suggest an idea for another article, contact Martha Waggoner at Martha.Waggoner@aicpa-cima.com.