SECTION 3. PROPOSED

APPLICABILITY DATES AND RELIANCE ON THE CAMT PROPOSED REGULATIONS AND FORTHCOMING PROPOSED REGULATIONS

.01 Purpose . In response to numerous comments received with respect to the CAMT Proposed Regulations outlining the concerns described in section 2.05(1) of this notice, the Treasury Department and the IRS have reconsidered the proposed applicability dates and reliance rules set forth in the “Proposed Applicability Dates and Reliance on the Proposed Regulations” section of the CAMT Proposed Regulations ( see 89 F.R. 75127). The Treasury Department and the IRS anticipate that the notice of proposed rulemaking that will partially withdraw the CAMT Proposed Regulations and contain the forthcoming proposed regulations will include a new “Proposed Applicability Dates and Reliance on the Proposed Regulations” section providing that no section (for example, proposed § 1.56A1) of the CAMT Proposed Regulations and the forthcoming proposed regulations would be applicable for any taxable year beginning before the date a corresponding section of a final regulation is published in the Federal Register . Accordingly, once published as final regulations in the Fed- eral Register, no section of the CAMT Proposed Regulations will apply, and no section of the forthcoming proposed regulations will apply, to any taxable year beginning before the date a corresponding section of a final regulation is published in the Federal Register .

.02 Taxable years beginning before final regulations .

(1) Reliance on CAMT Proposed Reg- ulations .

October 27, 2025 632 Bulletin No. 2025–44

with its Form 4626, Alternative Mini- mum Tax—Corporations, for a particular taxable year a statement describing the approach taken in completing Form 4626 for such taxable year and the guidance it relied upon for such taxable year. See page 2 of the instructions to Form 4626. ³