N-2023-64: Additional Interim Guidance Regarding the Application of the Corporate Alternative Minimum Tax under Sections 55, 56A, and 59 of the Internal Revenue Code

Notice 2023-64 provides additional interim guidance that is intended to further clarify the application of the new corporate alternative minimum tax (CAMT), as added to the Code by the Inflation Reduction Act of 2022. The Treasury Department and the IRS anticipate that forthcoming proposed regulations will provide rules that are consistent with the interim guidance. Specifically, it describes rules for determining a taxpayer?s applicable financial statement and adjusted financial statement income (AFSI), including rules applicable to tax consolidated groups and certain foreign corporations. It provides rules for AFSI adjustments for the depreciation of section 168 property, the amortization of qualified wireless spectrum, the treatment of certain taxes, and to prevent certain duplications and omissions. It also describes rules regarding the determination of applicable corporation status, the CAMT foreign tax credit, and financial statement net operating losses. Finally, it provides a request for comments and the procedure for submitting such comments.

Notice 2023-64 will be in IRB: 2023-40, dated 10/02/2023.

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