Notice 2025-28 provides interim guidance on the

application of the CAMT to partnerships and corporations that are partners in partnerships. The interim guidance simplifies the application of the CAMT by providing (i) optional top-down and taxable-income elections, and modified proposed section 1.56A-5 methods to compute a partner’s distributive share of a partnership’s AFSI, (ii) two optional methods to compute adjusted financial statement income attributable to partnership contributions and distributions, and (iii) that certain non-realization amounts are disregarded in computing AFSI. Taxpayers may rely on the guidance in Notice 2025-28 until further guidance is issued.