INCOME TAX

REG-112129-23, page 787. This notice of proposed rulemaking (NPRM) provides rules that would address the application of the corporate alternative minimum tax (CAMT) that is imposed on the adjusted financial statement income (AFSI) of certain corporations based on their applicable financial statement (AFS) for taxable years beginning after December 31, 2022. The proposed regulations would provide definitions and gen

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eral rules regarding the determination of AFSI. The proposed regulations also would provide guidance regarding identification of an AFS, various statutory and regulatory adjustments made in determining AFSI, the determination of whether a corporation is an applicable corporation subject to the CAMT, including rules for members of a foreign parented multinational group (FPMG), and the determination of the CAMT foreign tax credit. The proposed regulations also would provide guidance on the application of the CAMT to affiliated corporations filing a consolidated income tax return.