News & Analysis as of

Alternative Minimum Tax

The Alternative Minimum Tax is an aspect of the United States federal tax code that seeks to capture a minimum level of revenue from all taxpayers and to ensure that some earners are not escaping tax liability... more +
The Alternative Minimum Tax is an aspect of the United States federal tax code that seeks to capture a minimum level of revenue from all taxpayers and to ensure that some earners are not escaping tax liability through certain tax breaks or deductions.  Liability under the AMT is calculated by adding certain deductions back into an individual's adjusted gross income, subtracting the AMT exemption and then, paying a percentage of the remaining figure. less -
Vinson & Elkins LLP

CAMT Count Me Twice: Determining CAMT AFSI in Mergers and Acquisitions

Vinson & Elkins LLP on

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

Blake, Cassels & Graydon LLP

Principaux changements réglementaires et fiscaux touchant les fonds de capitaux privés

Blake, Cassels & Graydon LLP on

Comme les fonds de capitaux privés évoluent constamment, les investisseurs doivent composer avec un environnement de plus en plus complexe façonné par divers facteurs incontournables, notamment des réformes fiscales, des...more

Vinson & Elkins LLP

Why CAMT I Get Away From You: Losing Applicable Corporation Status Under the Corporate Alternative Minimum Tax

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On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

Allen Barron, Inc.

Update your Trust and Estate Plan Regularly to Protect Your Interests

Allen Barron, Inc. on

It is important to update your trust and estate plan regularly to protect your interests and meet the changing requirements of your future while integrating changes in law and best practices to provide for every potential...more

Eversheds Sutherland (US) LLP

Be careful what you wish for: IRS and Treasury release goliath CAMT NPRM full of nuance and complexity

Eversheds Sutherland (US) LLP on

On September 12, 2024, the Internal Revenue Service and Department of the Treasury (collectively, the Government) issued long-awaited proposed regulations (the NPRM), providing guidance regarding application of the corporate...more

Vinson & Elkins LLP

Treasury Releases Long-Awaited Proposed Regulations on the Corporate Alternative Minimum Tax

Vinson & Elkins LLP on

On September 12, 2024, the Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) issued long-awaited proposed regulations (89 FR 75062) (the “Proposed Regulations”) on the application of the...more

Foley & Lardner LLP

Unlocking the Power of Equity-Based Incentive Compensation: An Overview of Incentive Stock Options (ISOs)

Foley & Lardner LLP on

This article is the third in our series on equity-based compensation intended to assist employers with answering a common question: What type of equity compensation award is best for our company and our employees?...more

Cadwalader, Wickersham & Taft LLP

Mixed Opinions on Penalty Relief for Corporate AMT Taxpayers

Cadwalader, Wickersham & Taft LLP on

On April 15, the IRS released Notice 2024-33 (the “Notice”), offering limited relief from tax penalties for underpaying estimated income taxes arising from a corporation’s alternative minimum tax (“AMT”). The AMT imposes a...more

Holland & Hart - The Benefits Dial

I Seen a Girl on a One-Way Corridor, Stealing Down a Wrong-Way Street – Tax Opportunities with ISOs in M&A

Holland & Hart - The Benefits Dial on

by John Ludlum Incentive Stock Options (“ISOs”) have a somewhat legendary status as equity incentives for technology and other early-stage companies. It is true that ISOs are one of two types of equity awards that can achieve...more

Blake, Cassels & Graydon LLP

Budget fédéral 2024 : Présentation de certaines mesures fiscales

Blake, Cassels & Graydon LLP on

Le 16 avril 2024 (le « jour du Budget »), le gouvernement du Canada a présenté son budget fédéral de 2024 (le « Budget 2024 »). Bien que le principal élément du Budget 2024 soit une proposition visant à faire passer le taux...more

Blake, Cassels & Graydon LLP

2024 Federal Budget: Selected Tax Measures

Blake, Cassels & Graydon LLP on

On April 16, 2024 (Budget Day), the Government of Canada released its 2024 federal budget (Budget 2024). While the biggest headline item in Budget 2024 is a proposal to increase the capital gains inclusion rate from one-half...more

Ankura

Navigating the New Corporate Alternative Minimum Tax: Strategic Asset Allocation and Its Impact on M&A

Ankura on

The new corporate alternative minimum tax (CAMT) creates incentives for large companies to allocate more value to amortizing intangible assets and less value to assets like goodwill that do not amortize for book purposes. ...more

Blake, Cassels & Graydon LLP

What You Need to Know About the Pension Investment Landscape in 2024

Blake, Cassels & Graydon LLP on

The new year brings new considerations for pension fund and sovereign investors. Below are a few key topics to keep in mind going into 2024...more

Opportune LLP

Insight Into Hedge Accounting Elections & Corporate Alternative Minimum Tax Considerations

Opportune LLP on

The Inflation Reduction Act (IRA) of 2022 significantly changed the U.S. Federal income tax code, including introducing the new Corporate Alternative Minimum Tax (CAMT). The CAMT is a parallel tax system that applies to...more

Roetzel & Andress

IRS Issues Inflation Adjustments for 2024

Roetzel & Andress on

The IRS recently announced the 2024 annual inflation adjustments for key tax provisions. Of interest to our clients, • Standard Deduction: The standard deduction for married couples filing jointly increases by $1,500 to...more

Eversheds Sutherland (US) LLP

CAMT round three: The IRS and Treasury release third round of substantive CAMT guidance

Eversheds Sutherland (US) LLP on

On September 12, 2023, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released a third substantive piece of guidance, Notice 2023-64 (Notice) clarifying the application of the new corporate...more

Eversheds Sutherland (US) LLP

Relief from the heat: IRS provides penalty waiver for taxpayers not considering CAMT liability in 2023 estimated tax payments

Eversheds Sutherland (US) LLP on

On June 7, 2023, the IRS released Notice 2023-42 (the Notice), providing taxpayers relief from the addition to tax under Section 6655 in connection with the application of the new corporate alternative minimum tax (CAMT). In...more

Bennett Jones LLP

The Alternative Minimum Tax Goes Mainstream

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The 2023 Budget proposes material changes to the alternative minimum tax (AMT) regime which, as discussed below, could result in significant increases to taxes on capital gains (i.e.,5-6 percentage points). Although...more

Blake, Cassels & Graydon LLP

Budget fédéral 2023 : Présentation de certaines mesures fiscales

Blake, Cassels & Graydon LLP on

Le 28 mars 2023 (le « jour du Budget »), la ministre des Finances du Canada a présenté le budget fédéral de 2023 (le « Budget 2023 »). Même si certains avaient prédit que le programme législatif chargé du ministère des...more

Davies Ward Phillips & Vineberg LLP

Federal Budget 2023 – Major Changes for Business and High Net Worth Individuals

Davies Ward Phillips & Vineberg LLP on

On March 28, 2023 (Budget Day), the Honourable Chrystia Freeland, Deputy Prime Minister of Canada and Minister of Finance, delivered the Liberal Party’s federal budget (Budget 2023). Budget 2023 does not change the...more

Eversheds Sutherland (US) LLP

Charting a course: Guidance issued to help navigate potential issues for insurance industry with the corporate alternative minimum...

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On February 17, 2023, the Department of Treasury (Treasury) and the Internal Revenue Service (the IRS) issued Notice 2023-20 (the Notice), to provide guidance that is intended to help avoid unintended adverse consequences to...more

Davies Ward Phillips & Vineberg LLP

U.S. Tax Laws: A Review of 2022 and a Look Ahead to 2023

Davies Ward Phillips & Vineberg LLP on

As we settle into the new year, let’s take a moment to first consider last year’s tax developments and then take a look ahead to what 2023 might have in store for us. Review of U.S. Tax Developments in 2022- In 2022 we...more

Cadwalader, Wickersham & Taft LLP

Notice 2023-7 Provides Initial Guidance Regarding the Corporate Alternative Minimum Tax

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On December 27, 2022, Treasury issued Notice 2023-7, which provides guidance regarding the new Corporate Alternative Minimum Tax (“CAMT”) that taxpayers can rely on until Treasury publishes additional guidance. As mentioned...more

Holland & Knight LLP

Notice 2023-7: First Peek at Corporate AMT Guidance

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As promised, the U.S. Department of the Treasury (Treasury Department) and IRS on Dec. 27, 2022, issued guidance regarding the new corporate alternative minimum tax (CAMT) enacted as part of the Inflation Reduction Act (IRA)....more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Issues Initial Guidance for New Excise Tax on Stock Buybacks and Corporate Alternative Minimum Tax

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On December 27, 2022, the IRS issued two notices providing key initial guidance for the new excise tax on corporate stock buybacks and the new corporate alternative minimum tax (CAMT). Both the excise tax and the CAMT were...more

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