Comment from APA Corporation

Summary: APA Corporation, an independent energy company, is requesting specific guidance from the Treasury and IRS regarding the treatment of intangible drilling and development costs (IDCs) under the Corporate Alternative Minimum Tax (CAMT). They argue for a "tracing approach" to prevent the permanent loss of pre-2026 IDC deductions and request that guidance on embedded depreciation deductions in Net Operating Loss (NOL) carryovers be extended to include IDCs.