N-2023-7: Initial Guidance Regarding the Application of the Corporate Alternative Minimum Tax under Sections 55, 56A, and 59 of the Internal Revenue Code

Notice 2023-7 announces the intention of the Department of the Treasury and the Internal Revenue Service to issue proposed regulations addressing the application of the corporate alternate minimum tax (CAMT), as added to the Code by the Inflation Reduction Act of 2022. This notice describes the rules intended to be included in the forthcoming proposed regulations, including rules relating to certain issues regarding subchapters C and K of the Code, troubled corporations, groups of corporations filing a consolidated Federal income tax return, the depreciation of section 168 property, and the treatment of certain Federal income tax credits under the CAMT. The notice also provides a simplified method for determining whether a corporation is an "applicable corporation" subject to the CAMT. Finally, the notice provides a request for comments and the procedure for submitting such comments.

Notice 2023-7 will be in IRB: 2023-3, dated January 17, 2023.

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