The IRS has issued a notice saying that it intends to issue proposed regs (forthcoming proposed regulations) addressing the application of the new 15% corporate alternative minimum tax (CAMT). (Notice 2023-7, 2023-3 IRB; IR 2022-229)
The notice also provides interim guidance regarding certain time-sensitive issues intended to be addressed by the forthcoming proposed regulations. Taxpayers may rely on the guidance until the issuance of the forthcoming proposed regulations.
In addition, the IRS intends to issue additional interim guidance to address other CAMT issues prior to the issuance of the forthcoming proposed regulations. Such additional interim guidance is expected to address, among other issues, certain issues related to the treatment under the CAMT of items that are marked-to-market for financial statement purposes (such as life insurance company separate account assets and certain financial products), the treatment of certain items reported in other comprehensive income (OCI), and the treatment of embedded derivatives arising from certain reinsurance contracts. The IRS says that the additional interim guidance would be intended to help avoid substantial unintended adverse consequences to the insurance industry and certain other industries.
For more information about the CAMT, see Checkpoint’s Federal Tax Coordinator ¶S-3707.
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