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September 19, 2024
2024-1725

Wednesday, October 2 | Corporate alternative minimum tax: What the proposed regulations could mean for companies (1 pm ET)

On September 12, 2024, the Treasury Department issued over 600 pages of long-awaited proposed regulations (REG-112129-23) on the application of the 15% corporate alternative minimum tax (CAMT) on the adjusted financial statement income (AFSI) of large corporations. The proposed regulations propose comprehensive rules for applying CAMT.

Join our team of Ernst & Young LLP subject matter professionals for a discussion of the technical aspects and potential implications of the proposed regulations, including:

  • Whether a corporation is an "applicable corporation"
  • An entity's "applicable financial statement"
  • AFSI basics and transition rules
  • AFSI adjustments with respect to depreciable property
  • An entity's distributive share of AFSI with respect to a partnership investment
  • AFSI adjustments resulting from contributions of property to partnerships and distributions of property by partnerships
  • AFSI adjustments resulting from certain corporate transactions, including special rules that limit the use of acquired CAMT attributes
  • The application of the CAMT to affiliated corporations filing a consolidated income tax return
  • AFSI adjustments resulting from ownership of foreign corporation stock and transactions involving foreign corporations
  • AFSI adjustments for controlled foreign corporations
  • AFSI adjustments to prevent duplications and omissions
  • The calculation of the CAMT foreign tax credit
  • CAMT anti-abuse rules
  • The applicability date of the proposed regulations, including early-reliance options

Date: Wednesday, October 2, 2024

Time: 1:00-2:30 p.m. ET New York; 10:00-11:30 a.m. PT Los Angeles

Registration: Register for this event.

Panelists

Enrica Ma, Principal, National Tax — International Tax and Transaction Services, Ernst & Young LLP

Brian Peabody, Principal, National Tax — International Tax and Transaction Services, Ernst & Young LLP

Chris Mayer-Dempsey, Senior Manager, National Tax — Passthrough Transactions Group, Ernst & Young LLP

Rayth Myers, Senior Manager, National Tax — Accounting Periods, Methods & Credits, Ernst & Young LLP

Moderator

Tim Powell, Partner, National Tax — Accounting Periods, Methods & Credits, Ernst & Young LLP

CPE credit offered: up to 1.8 depending on duration. Recommended field of study: Taxes. Learning objective: Identify a) key provisions of the proposed regulations, including impacts from ownership of a foreign corporation; b) key aspects of CAMT covering partnerships; c) determination of AFSI, including treatment of mark-to-market gains and losses, certain corporate transactions, and depreciation. This intermediate level, group internet-based course has no prerequisites or advanced preparation. Final CPE award to be based on content, polling and length of participation. See CPE FAQ for more information.

EY webcast managed and produced by Ernst & Young LLP's Tax Technical Knowledge Services Group, Washington, DC: Lynn Fairfax | lynn.fairfax@ey.com and Barbara Kirchheimer | Barbara.Kirchheimer@ey.com

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The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.

 

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