Corporate Alternative Minimum Tax Applicable After 2022

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.

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.

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.

The American Chemistry Council (ACC) submitted comments on the proposed regulations for the Corporate Alternative Minimum Tax (CAMT), generally supporting the NPRM while requesting specific adjustments. They advocate for including deductible repair expenses in AFSI adjustments, adopting a cut-off or fresh start approach for tax attribute transitions, and simplifying foreign tax credit and partnership calculations.

The American Bankers Association (ABA) supports the proposed regulations for the Corporate Alternative Minimum Tax (CAMT) but requests a specific modification regarding investments made under the equity method of accounting. They argue that utilizing book income for these investments would more accurately reflect financial statement income, reduce significant compliance burdens for banks and social/environmental projects, and decrease costs for both taxpayers and the IRS.