Corporate Alternative Minimum Tax Applicable After 2022

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 American Council of Life Insurers (ACLI) opposes proposed regulations regarding Adjusted Financial Statement Income (AFSI) adjustments, specifically arguing that the requirement to carve out amounts attributable to pre-2020 taxable years is practically impossible and creates undue administrative burdens. They recommend aligning the final regulations with the previous Notice 2023-64 approach, which takes into account the full amount of cumulative adjustments from accounting principle changes.

The American Gas Association, representing over 200 local energy companies, supports the proposed regulations but requests specific modifications to provide greater flexibility for regulated utilities. They argue for adjustments regarding repair costs, extraordinary sales, and tax capitalization method changes to prevent disproportionate tax burdens and avoid distortive "cliff effects" regarding corporate status.

Coinbase, Inc. and MicroStrategy Incorporated are requesting that the Treasury Department adjust the Corporate Alternative Minimum Tax (CAMT) regulations to exclude unrealized gains and losses on cryptocurrency holdings from "adjusted financial statement income" (AFSI). They argue that the current interaction between CAMT and new accounting standards creates unintended tax consequences, violates constitutional principles regarding the realization of income, and creates a disadvantage for domestic corporations compared to foreign ones.