This article was originally published in Tax Notes on January 26, 2023

The Inflation Reduction Act (IRA), signed into law on August 16, 2022, directed new federal spending toward reducing carbon emissions, lowering healthcare costs, funding the Internal Revenue Service, and trying to improve taxpayer compliance.

It also created the Corporate Alternative Minimum Tax (CAMT), which imposed a 15% minimum tax on the adjusted financial statement income of large corporations for taxable years beginning after December 31, 2022.

Notice 2023-7, 2023-3 IRB 390, issued in December 2022, provides interim guidance on the CAMT, addressing some targeted concerns related to cancellation of debt income and companies emerging from bankruptcy, however, larger questions remain unanswered. 

Managing Director Kevin M. Jacobs recently spoke with Tax Notes, describing fact patterns that could present problems under the new tax for companies emerging from bankruptcy and the urgent need for guidance addressing those scenarios.