Insights from the EY Center for Tax Policy

Over the past few months, the Treasury Department has issued several notices regarding the application of the CAMT. The notices announce the Treasury Department's intent to withdraw the existing proposed CAMT regulations (REG-112129-23) and issue new proposed CAMT regulations at a later date. The notices also: (1) provide new interim guidance on several issues that taxpayers can rely on until the new proposed CAMT regulations are issued, (2) delay the proposed applicability dates of forthcoming final CAMT regulations, and (3) provide more flexible options for relying on aspects of the existing proposed CAMT regulations prior to their withdrawal.

Join our team of Ernst & Young LLP subject matter professionals for a discussion of the technical aspects and potential implications of the interim guidance provided in Notice 2025-27, Notice 2025-28, Notice 2025-46, and Notice 2025-49, including:

• A new safe harbor for determining whether a corporation is an "applicable corporation"
• Adjusted financial statement income (AFSI) adjustments that result from ownership of a partnership interest and transactions involving partnerships
• AFSI adjustments that result from ownership of stock of a domestic corporation and transactions involving domestic corporations
• AFSI adjustments for troubled companies
• The determination of AFSI for a tax consolidated group
• The utilization of financial statement net operating losses
• New AFSI adjustments, including AFSI adjustments for certain unrealized gains and losses, industry specific AFSI adjustments, and AFSI adjustments for acquired goodwill
• Options for relying on the existing proposed CAMT regulations and the interim guidance in the notices

Date: Thursday, November 6, 2025

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

Tim Kerr, Partner, National Tax — International Tax and Transaction Services, Ernst & Young LLP

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

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

Marie Milnes-Vasquez, Managing Director, National Tax — International Tax and Transaction Services, Ernst & Young LLP

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

Jeshua Wright, Partner, National Tax — International Tax and Transaction Services, 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 objectives: Identify key AFSI adjustments provided by the recent CAMT notices, understand the new options for relying on the existing proposed CAMT regulations, and understand the options for relying on the new interim guidance provided by the recent CAMT notices. 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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