Compliance
Current Corporate Alternative Minimum Tax: What Businesses Should Do Now
Recent guidance clarifies CAMT rules, adjustments, and anti-abuse measures; here’s what affected corporations must prepare for.
By NomadicTax Research Team • 5-8 min read • April 9, 2026
## What Is the Corporate Alternative Minimum Tax (CAMT)?
CAMT is a tax on large corporations, introduced by the Inflation Reduction Act, intended to ensure that corporations with large financial reporting income pay a minimum level of tax. **Applies to taxable years beginning after 2022**. ([irs.gov](https://www.irs.gov/pub/irs-irbs/irb26-11.pdf?utm_source=openai))
## Recent IRS/Treasury Guidance in Notice 2026-7
In *Bulletin No. 2026-11* (March 9, 2026), Notice 2026-7 provides **additional interim guidance** on CAMT application:
- Adjustments to **Adjusted Financial Statement Income (AFSI)** rules.
- Clarification on **financially troubled companies** and **anti-abuse rules** for covered asset transactions including intangibles under section 367(d). ([irs.gov](https://www.irs.gov/pub/irs-irbs/irb26-11.pdf?utm_source=openai))
- Guidance on applicability dates and what taxpayers can rely on, especially regarding previous Notice 2025-49 and this notice. ([irs.gov](https://www.irs.gov/pub/irs-irbs/irb26-11.pdf?utm_source=openai))
## Who Is Affected?
- Large corporations whose financial statement income exceeds certain thresholds, subject to CAMT requirements. Those that have covered transactions and those owning intangible property are especially impacted. ([irs.gov](https://www.irs.gov/pub/irs-irbs/irb26-11.pdf?utm_source=openai))
- Companies engaged in cross-border transactions dealing with section 367(d), where property transfer under foreign vs domestic arrangements matters. ([irs.gov](https://www.irs.gov/pub/irs-irbs/irb26-11.pdf?utm_source=openai))
## Actionable Steps for Businesses
1. **Review financial statements** and assess AFSI adjustments under CAMT to project tax liability.
2. For groups with intangible property transactions, map out transfers, especially section 367(d) transactions, to identify potential room for anti-abuse rules to apply. Involve transfer pricing and legal teams.
3. Monitor finalized regulations — current guidance is interim; policies may shift when rules are finalized. ([irs.gov](https://www.irs.gov/pub/irs-irbs/irb26-11.pdf?utm_source=openai))
4. Engage tax advisors early to test what qualifies as “financially troubled” and how that affects eligibility or relief provisions.
## Practical Example
- A corporation with $500 million in income from financial statements but materially lower taxable income due to deductions may find its CAMT base increased by restoring non-deductible expenses under AFSI adjustments.
- A tech company transferring IP abroad under section 367(d) may now be subject to stricter scrutiny and potential adjustment; plan carefully around timing and documentation.
## Timeline and What’s Next
- These interim rules are effective **now** and can be relied upon in tax years for which guidance is applicable. ([irs.gov](https://www.irs.gov/pub/irs-irbs/irb26-11.pdf?utm_source=openai))
- Final regulations are expected later; until then, taxpayers relying on these interim rules should document their positions clearly.
- Consider updating internal tax models and compliance processes **immediately** to account for CAMT exposure.
For corporations, this isn’t just a compliance detail—it’s a strategic imperative. With CAMT in full swing, understanding adjustments, avoiding surprises, and maintaining transparent documentation are your best protections.