SECTION 4. LIMITED — Internal Revenue Bulletin 2024-27

OF ADDITION TO TAX FOR UNDERPAYMENT OF ESTIMATED INCOME TAX

.01 Waiver . In light of the continuing challenges associated with determining whether a corporation is an Applicable Corporation and the amount of a corporation’s CAMT liability under § 55, and in the interest of sound tax administration, the IRS will waive the portion of the addition to tax under § 6655 that is attributable to a corporation’s CAMT liability, for an installment of estimated tax with respect to a taxable year that began in 2024 that is due on or before August 15, 2024. Accordingly, a corporate taxpayer’s required installment of estimated tax that is due on or before August 15, 2024, need not include amounts attributable to its CAMT liability under § 55 to prevent the imposition of an addition to tax under § 6655. If a corporation fails to timely pay its CAMT liability under § 55 when due, other sections of the Code may apply; for example, additions to tax could be imposed under § 6651 if payment of the CAMT liability is not made by the due date (without regard to any extension) of the corporation’s return.

.02 Instructions to be modified . Affected taxpayers must file Form 2220 with their Federal income tax return, even if they owe no estimated tax penalty, to avoid a penalty notice. The instructions to Form 2220, Underpayment of Estimated Tax by Corporations, will be modified to provide specific instructions on how to avoid a penalty notice. The instructions also will clarify that no addition to tax will be imposed under § 6655 based on a corporation’s failure to make an estimated tax payment of its CAMT liability under § 55, for an installment of estimated tax with respect to a taxable year that began in 2024 that is due on or before August 15, 2024, and that a taxpayer may exclude such amounts when calculating

the amount of its required annual payment on Form 2220 for purposes of calculating the installments of estimated tax for which relief is provided. The modified instructions will be posted on https://www.irs. gov .