The two notices, Notice 2025-46 and Notice 2025-49, on 30 September 2025, provide interim guidance on the corporate alternative minimum tax (CAMT).
The US Internal Revenue Service (IRS) issued two notices, Notice 2025-46 and Notice 2025-49, on 30 September 2025, providing interim guidance on the corporate alternative minimum tax (CAMT).
The IRS also announced plans to withdraw the September 2024 partially proposed regulations and replace them with revised proposed rules reflecting the new interim guidance and prior notices (2025-27 and 2025-28).
Notice 2025-46
This notice provides interim guidance regarding the application of the corporate alternative minimum tax (CAMT) to domestic corporate transactions, financially troubled companies (troubled companies), and tax consolidated groups.1 The Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to partially withdraw the CAMT Proposed Regulations (as described in section 2.03 of this notice) and to issue revised proposed regulations that include proposed rules similar to the interim guidance provided in sections 3 through 6 of this notice (forthcoming proposed regulations).2 The forthcoming proposed regulations would reduce the compliance burdens and costs associated with the application of the CAMT to domestic corporate transactions, troubled companies, and tax consolidated groups. Taxpayers may rely on the interim guidance provided in sections 3 through 6 of this notice as provided in section 7 of this notice.
Notice 2025-49
This notice provides additional interim guidance regarding the application of the corporate alternative minimum tax (CAMT) under §§ 55, 56A, and 59 of the Internal Revenue Code (Code).1 Prior to the publication of any final regulations relating to the CAMT, the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to partially withdraw the CAMT Proposed Regulations (as defined in section 2.03 of this notice) and to issue revised proposed regulations (forthcoming proposed regulations) that, in part, are anticipated to include rules similar to the interim guidance described in sections 3 through 10 of this notice, Notice 2025-27, 2025-26 I.R.B. 1611 (June 23, 2025), Notice 2025-28, 2025-34 I.R.B. 316 (August 18, 2025), and Notice 2025-46, 2025-43 I.R.B. ____ (20 October 2025).
Section 3 of this notice addresses the applicability dates and reliance rules provided in the CAMT Proposed Regulations. Section 4 of this notice addresses an adjustment to adjusted financial statement income (AFSI)2 for a taxpayer with regulated operations that capitalizes certain costs as regulatory assets under Accounting Standards Codification (ASC) 980 in its applicable financial statement (AFS). Section 5 of this notice addresses adjustments to AFSI for certain items measured at fair value. Section 6 of this notice addresses an adjustment to AFSI for CAMT entities that are subject to the tonnage tax regime.
Section 7 of this notice addresses an adjustment to AFSI for certain depreciation deductions that previously gave rise to a carryover of a net operating loss (NOL), as defined in § 172(c), for regular tax purposes. Section 8 of this notice addresses an adjustment to AFSI for nonlife insurance companies that carry back an NOL for regular tax purposes. Section 9 of this notice addresses an adjustment to AFSI for § 197 amortization attributable to tax goodwill acquired in certain transactions. Section 10 of this notice addresses adjustments to AFSI for accounting principle change adjustments and restatements of a prior-year AFS. Section 11 of this notice requests comments on the issues relating to section 5 of this notice.
The proposed regulations will officially apply to tax years starting on or after their finalisation, but taxpayers can choose to follow any section earlier, as long as they apply it consistently to all prior years.
