Corporate Alternative Minimum Tax Applicable After 2022

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.

The Affordable Housing Tax Credit Coalition (AHTCC), a trade association representing stakeholders in the affordable housing industry, supports the IRS's efforts to simplify the Corporate Alternative Minimum Tax (CAMT). They specifically advocate for a "top-down" approach for partnership investments using the equity method of accounting and the expansion of taxable income elections to reduce administrative burdens and protect tax equity investment.

The American Bankers Association supports the overall Corporate Alternative Minimum Tax (CAMT) regulatory regime but requests specific modifications to simplify compliance. They argue for the inclusion of an alternative "top-down election" using book income for equity method investments and the expansion of the "taxable income election" to all tax equity partnerships to reduce administrative burdens for both taxpayers and the IRS.

Nationwide Mutual Insurance Company supports the proposed regulations but argues that they should include a specific transition rule for pre-2023 nonlife net operating loss (NOL) carryforwards. They contend that without this adjustment to adjusted financial statement income (AFSI), the Corporate Alternative Minimum Tax (CAMT) would unfairly penalize taxpayers for taxes effectively prepaid before the CAMT was in effect.

The AES Corporation, a global energy company, submitted comments regarding proposed regulations on the Corporate Alternative Minimum Tax (CAMT). They advocate for specific modifications to the "safe harbor" method and partnership rules to ensure consistency in how tax credits and distributive shares are treated, aiming to reduce administrative burdens for domestic energy developers.

The American Council on Renewable Energy (ACORE), American Clean Power Association (ACP), and Solar Energy Industries Association (SEIA) are submitting joint comments regarding the Corporate Alternative Minimum Tax (CAMT). They argue that the proposed "bottom-up" calculation method for partnership income creates significant distortions and compliance burdens for clean energy tax equity investments, and they request the implementation of a "Top-Down Election" to ensure more accurate and efficient results.

Jackson National Life Insurance Company opposes the proposed bifurcation of accounting principle change amounts for pre-2020 taxable years under Prop. Reg. §1.56A-17. The company argues that this bifurcation is impractical to calculate, inconsistent with statutory language, and would create the very duplications or omissions the regulation intends to prevent.

The Securities Industry and Financial Markets Association (SIFMA) supports the implementation of the Corporate Alternative Minimum Tax (CAMT) but argues that the Proposed Regulations introduce excessive complexity and compliance burdens. They advocate for several modifications, including a "top-down" election for partnership interests to simplify AFSI calculations and the ability to elect out of "deferred sale" provisions to align the tax with book income.