SECTION 1. OVERVIEW

This notice provides additional interim guidance regarding the application of the corporate alternative minimum tax (CAMT) under §§ 55, 56A, and 59 of the Internal Revenue Code (Code). ¹ Prior to the publication of any final regulations relating to the CAMT, the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to partially withdraw the CAMT Proposed Regulations (as defined in section 2.03 of this notice) and to issue revised proposed regulations (forthcoming proposed regulations) that, in part, are anticipated to include rules similar to the interim guidance described in sections 3 through 10 of this notice, Notice 2025-27, 2025-26 I.R.B. 1611 (June 23, 2025), Notice 202528, 2025-34 I.R.B. 316 (August 18, 2025), and Notice 2025-46, 2025-43 I.R.B. ____ (October 20, 2025).

Section 3 of this notice addresses the applicability dates and reliance rules provided in the CAMT Proposed Regulations. Section 4 of this notice addresses an adjustment to adjusted financial statement income (AFSI) ² for a taxpayer with regulated operations that capitalizes certain costs as regulatory assets under Accounting Standards Codification (ASC) 980 in its applicable financial statement (AFS). Section 5 of this notice addresses adjustments to AFSI for certain items measured at fair value. Section 6 of this notice addresses an adjustment to AFSI for CAMT entities that are subject to the tonnage tax regime. Section 7 of this notice addresses an adjustment to AFSI for certain depreciation deductions that previously gave rise to a carryover of a net operating loss (NOL),

as defined in § 172(c), for regular tax purposes. Section 8 of this notice addresses an adjustment to AFSI for nonlife insurance companies that carry back an NOL for regular tax purposes. Section 9 of this notice addresses an adjustment to AFSI for § 197 amortization attributable to tax goodwill acquired in certain transactions. Section 10 of this notice addresses adjustments to AFSI for accounting principle change adjustments and restatements of a prior-year AFS. Section 11 of this notice requests comments on the issues relating to section 5 of this notice.