The corporate alternative minimum tax (CAMT) was introduced in 2022 by the Inflation Reduction Act. The CAMT imposes a 15% minimum tax on the adjusted financial statement income (AFSI) of large corporations for taxable years beginning after Dec. 31, 2022. It generally applies to large corporations with average annual financial statement income exceeding $1 billion. Recent IRS guidance (Notice 2024-10) provides rules for determining the AFSI of a U.S. shareholder when a controlled foreign corporation (CFC) pays a dividend to the shareholder or another CFC. It also clarifies rules for determining the applicable financial statement of a corporation that’s included on a consolidated tax return.
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