The US Internal Revenue Service (IRS) has published Notice 2024-33, providing relief from penalties for underpayment of estimated income tax due to a portion of a corporation’s Corporate Alternative Minimum Tax (CAMT) liability. This penalty relief applies to estimated taxes due on or before 15 April 2024 or by 15 May 2024 for taxpayers whose taxable year begins in February 2024.

The overview and scope are as follows:

Section 1. Overview

This notice provides a limited waiver of the addition to tax under § 6655 of the Internal Revenue Code (Code)1 for underpayment of estimated income tax by a corporation to the extent the amount of any underpayment is attributable to a portion of a corporation’s corporate alternative minimum tax (CAMT) liability under § 55, as amended by § 10101 of Public Law 117-169, 136 Stat. 1818 (16 August 2022), commonly referred to as the Inflation Reduction Act of 2022 (IRA).

Section 2. Scope

The relief provided in this notice applies only for the purpose of calculating the installment of estimated income tax of a corporate taxpayer that is due on or before 15 April 2024 or, in the case of a fiscal year taxpayer with a taxable year beginning in February 2024, 15 May 2024, with respect to a taxable year that began during 2024. This notice waives any addition to tax under § 6655 to the extent the amount of any underpayment is attributable to the portion of the CAMT liability due in that installment.

Regarding calculating the amounts of installments of estimated income tax of a corporate taxpayer (or consolidated group) due after 15 April 2024, or after 15 May 2024 (in the case of a fiscal year taxpayer with a taxable year beginning in February 2024), § 6655 applies in the normal course, and this notice does not apply, nor does it waive the addition to tax under § 6655 to the extent the amount of any underpayment is attributable to provisions of the Code other than §§ 55(a) and (b)(2), 56A, and 59(k) and (l).