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Notice 2025-46

SECTION 1. OVERVIEW

Internal Revenue Bulletin 2025-43 · 2026-10-03 edition · updated 2026-10-04 · United States

This notice provides interim guidance regarding the application of the corporate alternative minimum tax (CAMT) to domestic corporate transactions, financially troubled companies (troubled companies), and tax consolidated groups. 1 The Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to partially withdraw the CAMT Proposed Regulations (as described in section 2.03 of this notice) and to issue revised proposed regulations that include proposed rules similar to the interim guidance provided in sections 3 through 6 of this notice (forthcoming proposed regulations). 2 The forthcoming proposed regulations would reduce the compliance burdens and costs associated with the application of the CAMT to domestic corporate transactions, troubled companies, and tax consolidated groups. Taxpayers may rely on the interim guidance provided in sections 3 through 6 of this notice as provided in section 7 of this notice.

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▸Contents — Internal Revenue Bulletin 2025-43

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