Published by Tax Notes

During a recent tax conference in Washington, D.C., tax advisors seeking answers to questions raised by proposed regulations implementing the corporate alternative minimum tax (CAMT) got some clarifications from an IRS official who helped craft the rules.

In addition, Kevin M. Jacobs — Managing Director and National Tax Office Practice Leader with A&M Tax — provided critical commentary on areas of the proposed CAMT rules that still require clarification, particularly those regarding taxpayer reliance. Jacobs pointed out the difference between “following” the proposed rules, relying on them generally, and being able to definitively rely on them to avoid an IRS challenge. “There is a big difference between what I view as capital R reliance versus lowercase r reliance, and whether or not the IRS can challenge the position you’re taking on a tax return,” Jacobs said.
 

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