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Internal Revenue Manual Part 3. Submission Processing · 2026-10-03 edition · updated 2026-10-04 · United States
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The CAMT applies to domestic and foreign tax forms.
An applicable corporation under IRC 59(k) is any corporation that satisfies the AFSI test for one or more tax years which are prior to the current tax year, and which end after December 31, 2021. A corporation meets the general AFSI test for that tax year when the corporation’s average annual AFSI for the 3-tax-year period ending with the tax year exceeds $1 billion. NOTE: All AFSI of members of a controlled group is included in the AFSI of the corporation for AFSI test purposes.
For the first tax year beginning after December 31, 2022, a corporation may choose to apply the safe harbor method (simplified method) for purposes of determining whether it is an applicable corporation. See Notice 2023-7, section 5, for additional information. If a corporation has been in existence for less than 3 tax years of the 3-tax-year period, the AFSI test is applied by averaging the tax years of the 3-tax-year period during which the corporation existed. AFSI for any tax year of fewer than 12 months shall be annualized by multiplying the AFSI for the short period by 12 and dividing the result by the number of months in the short period. NOTE: See Form 4626 Instructions for additional information on ASFI and the ASFI test applicable to Foreign-Parented Multinational Groups (FPMG) (FPMG AFSI Test).
CAMT applies if the tentative minimum tax for the tax year exceeds the sum of the regular income tax plus the base erosion minimum tax (imposed under IRC 59A). The tentative minimum tax for the tax year is the excess of 15% of AFSI for the tax year, over the CAMT Foreign Tax Credit (FTC) for the tax year. For any corporation that is not an applicable corporation, the tentative minimum tax for the tax year is zero. See Form 4626 and the Form 4626 instructions for additional information on calculating CAMT.
A corporation may take a credit against regular tax for alternative minimum tax (including CAMT) incurred in prior years. See Form 8827, Credit for Prior Year Minimum Tax—Corporations, for details.
A new field on entity module BMFOLE and ENMOD display TCAMT for a sum total of CAMT, which updates anytime a new return with CAMT or an adjustment to CAMT is input.
Math verify Form 4626, Alternative Minimum Tax - Corporations, in addition to any other parent form lines that impact tax (from the point of error). If a correction needs to be made to CAMT, adjust with REQ54, using Item Reference Number (IRN) 905 for increase or decrease.
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