Notice 2025-46 provides interim guidance on the

application of the CAMT to domestic corporate transactions, financially troubled companies, tax consolidated groups, and acquired financial statement net operating losses and certain built-in items. The interim guidance would simplify the application of the CAMT to domestic corporations by: (i) more closely aligning the rules for domestic corporate transactions with regular tax rules applicable to those transactions, but using CAMT inputs; (ii) clarifying the application of sections 108 and 1017 to troubled companies; (iii) simplifying the application of rules applicable to tax consolidated groups by incorporating by reference, with appropriate modifications, certain rules in the consolidated return regulations; and (iv) providing that the limitations on the use of acquired financial statement net operating losses and certain built-in items do not apply for purposes of computing AFSI. Taxpayers may rely on Notice 2025-46 until proposed regulations are issued.