Interim guidance recently issued by the IRS on the Sec. 55 corporate alternative minimum tax (AMT) contains several changes that the AICPA recommended.
One such change in Notice 2025-28 is the inclusion of a top-down elective safe harbor that will allow corporate AMT entity partners to use a simplified method for allocating their distributive share of a partnership’s adjusted financial statement income (AFSI).
Overall, the notice informs taxpayers of the intention of Treasury and the IRS to partially withdraw proposed regulations (REG-112129-23) and issue revised proposed regulations regarding the application of the corporate AMT to applicable corporations with financial statement income attributable to investments in partnerships.
The notice also provides interim guidance primarily on simplified methods to determine an applicable corporation’s AFSI concerning an investment in a partnership, reporting by partnerships of information needed to compute ASFI, and rules for partnership contributions and distributions. See more AICPA-recommended changes.