The US Internal Revenue Service issued Notice 2026-7 on 18 February 2026, providing additional interim guidance on the Corporate Alternative Minimum Tax (CAMT). The notice addresses key adjustments to income in the financial statements, including deductible tax repairs, intangible amortisation, research expenditures, and production costs, while clarifying anti-abuse rules and revising prior guidance for financially troubled companies.
The Internal Revenue Service (IRS) released Notice 2026-7 on 18 February 2026, setting out further interim guidance on the application of the Corporate Alternative Minimum Tax. The notice is scheduled for publication in the Internal Revenue Bulletin 2026-11 on 9 March 2026.
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).
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 issue proposed regulations (forthcoming proposed regulations) that are anticipated to include rules similar to the interim guidance provided in sections 3 through 10 of this notice, Notice 2025-27, 2025-26 I.R.B. 1611 (23 June 2025), Notice 2025-28, 2025-34 I.R.B. 316 (18 August 2025), Notice 2025-46, 2025-43 I.R.B. 533 (20 October 2025), and Notice 2025-49, 2025-44 I.R.B. 627 (27 October 2025).
Section 3 of this notice modifies the interim guidance provided in section 4 of Notice 2025-49 and addresses an adjustment to adjusted financial statement income (AFSI) for deductible tax repairs with respect to section 168 property.
Section 4 of this notice modifies the interim guidance provided in section 9 of Notice 2025-49 and addresses an adjustment to AFSI for § 197 amortisation attributable to certain intangibles.
Section 5 of this notice addresses an adjustment to AFSI for amortisation of domestic research or experimental expenditures.
Section 6 of this notice addresses an adjustment to AFSI for certain production costs attributable to film, television, live theatrical, and sound recording productions.
Section 7 of this notice addresses an adjustment to AFSI for certain low acquisition cost tangible property treated as materials and supplies.
Section 8 of this notice clarifies and modifies the interim guidance for financially troubled companies provided in section 4 of Notice 2025-46.
Section 9 of this notice addresses modifications to the anti-abuse rule in proposed § 1.56A-4 of the CAMT Proposed Regulations (as defined in section 2.03(1) of this notice) that would apply to certain covered asset transactions.
Section 10 of this notice addresses certain CAMT consequences of transactions involving intangible property subject to § 367(d).
Section 11 of this notice addresses applicability dates and the ability of taxpayers to rely on the interim guidance provided in Notice 2025-49 and this notice.
This notice is effective starting 18 February 2026.
