Tax insight

Interim guidance simplifies application of the Corporate Alternative Minimum Tax to partnerships

Insight
7 minute read
August 08, 2025

What happened?

Treasury and the IRS issued Notice 2025-28 (the Notice) on July 29, 2025, indicating an intent to partially withdraw proposed Corporate Alternative Minimum Tax (CAMT) regulations that relate to partnerships and providing interim guidance simplifying the application of CAMT to partnerships. Revised proposed regulations (forthcoming proposed regulations) will include rules similar to the interim guidance provided in the Notice.

Why is it relevant?

The Notice provides new elections and methods for determining a CAMT partner’s distributive share of adjusted financial statement income (AFSI) with respect to a partnership investment. Taxpayers may choose to apply these new elections and methods or continue to rely on prior guidance.

Action to consider 

Taxpayers should evaluate the new options available to them while there is still time to make changes in federal income tax returns for 2024 without having to amend or file administrative adjustment requests (AARs). Calendar year partnerships and corporations on extension wishing to apply the guidance contained in the Notice have until September 15, 2025 and October 15, 2025, respectively.