SECTION 4. LIMITED WAIVER OF

ADDITION TO TAX

.01 Waiver . In light of the continued uncertainty with respect to tax positions determined by applicable corporations following the publication of the CAMT Proposed Regulations, and in the interest of sound tax administration, the IRS will waive the addition to tax under § 6655 with respect to a corporation’s CAMT liability under § 55 for any taxable year that begins after December 31, 2024, and before January 1, 2026 (Covered CAMT Year). Accordingly, for a Covered CAMT Year, a corporation’s required installments of estimated tax 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

June 23, 2025 1614 Bulletin No. 2025–26

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 . The instructions to Form 2220, Underpay- ment of Estimated Tax by Corporations, will be modified, as necessary, to 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 any Covered CAMT Year, and that a taxpayer may exclude such amounts when calculating the amount of its required annual payment on Form 2220. The modified instructions will be posted on https:// www.irs.gov.

.03 Instructions to avoid penalty notice . Taxpayers seeking the relief provided in this notice (affected taxpayers) must file Form 2220 with their Federal income tax return, even if they owe no estimated tax penalty. The Form 2220 must be completed without including the CAMT liability from Schedule J of Form 1120, U.S. Corporation Income Tax Return (or other appropriate line of the corporation’s income tax return in the Form 1120 series). Affected taxpayers must also include an amount of estimated tax penalty on Line 34 of their Form 1120 (or other appropriate line of the corporation’s income tax return in the Form 1120 series), even if that amount is zero. Failure to follow these instructions could result in affected taxpayers receiving a penalty notice that will require an abatement request to apply the relief provided by this notice.

.04 Applicability . The waiver of the addition to tax imposed by § 6655 described in section 4.01 of this notice applies for any Covered CAMT Year.