PwC | IRS Issues New Interim CAMT Guidance

The IRS on September 30 released Notice 2025-46 and Notice 2025-49 , providing interim guidance on the corporate alternative minimum tax (CAMT). These notices address a broad range of issues, including rules for domestic corporate transactions, troubled companies, consolidated groups, financial statement adjustments, and numerous other provisions including mark-to-market adjustments, repair expenditures for certain regulated taxpayers, and certain “eligible” Section 197 goodwill. The guidance offers meaningful relief and clarity for taxpayers as they navigate CAMT compliance ahead of final regulations.

PwC will publish additional detailed insights on the guidance in the coming days.

Why is it relevant?
The interim guidance in Notices 2025-46 and 2025-49 builds on prior proposed regulations and notices, offering expanded options and targeted rules to prevent distortions in adjusted financial statement income (AFSI). The notices preview the intention of Treasury and the IRS to withdraw and repropose certain portions of last year’s proposed regulations, particularly those affecting book expense adjustments, partnership and intercompany rules, accounting principle changes, domestic corporate transactions, troubled company provisions, and numerous additional provisions.

The interim guidance in Notices 2025-46 and 2025-49 covers the following areas:

– Domestic corporate transactions: Clarifies the treatment of mergers, acquisitions, and other covered transactions for CAMT purposes.
– Troubled companies: Provides rules for insolvency, bankruptcy, and discharge of indebtedness, including limitations on the use of acquired financial statement net operating losses (FSNOLs).
– Consolidated groups: Updates AFSI and attribute rules for tax consolidated groups, including coordination with subchapter R and the tonnage tax regime.
– Financial statement adjustments: Addresses changes in accounting principles, restatements, and the treatment of fair value items and hedging transactions.
– Specific provisions: Introduces targeted adjustments for repair expenditures incurred by regulated taxpayers, shipping (tonnage tax regime), certain “eligible” Section 197 amortization, and insurance (NOL carrybacks), among others.
– Elections and reporting: Outlines procedures for making optional elections, such as the fair value item (FVI) exclusion and hedge coordination and details the requirement to attach explanatory statements to tax returns.

Actions to consider
Taxpayers should carefully review the new interim rules and consider their impact on 2024 and 2025 tax year planning and compliance. Key actions include:

– Evaluating whether recent or planned corporate transactions or restructurings fall within the scope of the new interim CAMT rules.
– Considering optional elections such as the FVI exclusion or hedge coordination option, which require statements attached to returns.
– Planning for reporting: taxpayers relying on interim guidance must attach explanatory statements to Form 4626, Alternative Minimum Tax – Corporations, or their corporate income tax returns.
– Monitoring for forthcoming regulations, which are expected to adopt rules consistent with these notices.

For more information, please contact:
Ed Geils, Global and US Tax Knowledge Management Leader, PwC US

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