The American Institute of CPAs (AICPA) has asked the US Department of the Treasury and the Internal Revenue Service (IRS) for more clarity and simplification on three recent Corporate Alternative Minimum Tax (CAMT) notices.
In a letter, the group pointed to issues it said are still unresolved.
The AICPA said its recommendations are intended to reduce compliance burdens, avoid double counting of income, improve consistency between financial and tax reporting, and make the CAMT rules easier to apply.
The letter focuses on purchase accounting and push-down accounting, domestic research and experimental expenditures under section 174A, intangible drilling costs, and the Controlled Foreign Corporations (CFC) double counting issue.
One of the main requests is for Treasury and the IRS to withdraw the purchase accounting and push-down accounting adjustment rules, along with the related interim rule in Section 3.04(3) of Notice 2025-46.
The AICPA said those rules require taxpayers to reverse purchase accounting and push-down accounting adjustments for CAMT purposes.
It argued that removing them would better match the statutory intent of CAMT and reduce compliance difficulties.
The group also asked for guidance under section 56A(c)(15) and section 56A(e) on how applicable financial statement income should be coordinated with domestic research and experimental spending under section 174A.
It recommended a targeted adjustment that would allow tax recovery to be reflected in applicable financial statement income when book recovery is slower, while preventing double deductions.
On consolidated groups, the AICPA said a common parent, or another designated agent, should be allowed to file a single Form 4626 for a CAMT tax consolidated group.
Under its proposal, CAMT would be calculated on a tax consolidated group basis. The tax liability and related attributes would then be allocated among separate regular tax consolidated return groups using an administrable method.
The letter said further guidance is needed in this area to improve administrability and avoid disputes between taxpayers and the government.
The AICPA also asked for more clarity on the adjustment under section 56A(c)(13), as amended by the OBBBA.
On the CFC double counting issue, the group said taxpayers should not have to early adopt multiple separate provisions in order to obtain relief.
AICPA Tax Policy & Advocacy senior manager Reema Patel said: “The AICPA’s recommendations focus on reducing unnecessary complexity, improving administrability and aligning the CAMT framework with its statutory intent and policy objectives.
