Cross-Border CAMT: Unpacking the International Aspects of the New IRS Notice

On September 12, 2023, the government released Notice 2023-64, the fourth piece of interim guidance on the corporate alternative minimum tax (CAMT), enacted as part of the Inflation Reduction Act in August 2022. The Notice provides guidance on a variety of cross-border CAMT issues, including which financial statements should be used (and how to derive financial statement income of the taxpayer from such statements), how to account for CFC income, the special aggregation rules for foreign-parented multinational groups, and the CAMT foreign tax credit. In this episode of Inside International Tax, we explore these key aspects of the Notice. What issues does the Notice resolve and what new questions does the Notice raise? How does the Notice interact with the prior CAMT notices and how do we think about what’s yet to come? How should taxpayers account for CFC dividends after the Notice?

Join us as our co-hosts Gary Scanlon and Kristen Gamboa are joined by Ron Dabrowski, Jonathan Galin, and Seevun Kozar from the KPMG WNT International Tax group to explore these issues and more on the latest episode of Inside International Tax.