Letter to the IRS Regarding the Corporate Alternative Minimum Tax

RE: Comments on REG-112129-23, Regarding the Corporate Alternative Minimum Tax

To Whom it May Concern:

The American Bankers Association (ABA) submits these comments in response to the request for comments in REG-112129-23, issued by the Department of the Treasury ("Treasury") and the Internal Revenue Service (IRS) regarding the corporate alternative minimum tax (CAMT) generally imposed under Sections 55, 56A, and 59 (the "Proposed Regulations").

The Proposed Regulations provide useful guidance on a plethora of CAMT considerations, including guidance on calculating adjusted financial statement income (AFSI) and identifying applicable corporations that are subject to the CAMT.

The Proposed Regulations also generally implement ABA’s prior request3 to provide rules for determining AFSI with respect to the receipt of federal financial assistance (FFA), within the meaning of Section 597(c)—generally arising in the context of bank acquisitions of troubled financial institutions.

ABA acknowledges and appreciates Treasury and the IRS's efforts in promulgating these Proposed Regulations—and ABA would like to specifically thank Treasury and the IRS for implementing ABA’s requested relief for FFA gain in Section 597 transactions.

Still, as discussed below in more detail, ABA recommends Treasury and the IRS make several changes to the Proposed Regulations prior to finalization.

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Letter to the IRS Regarding the Corporate Alternative Minimum Tax

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Letter to the IRS Regarding the Corporate Alternative Minimum Tax

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