Compliance

Effective Use of CAMT Guidance: What Corporations Should Know Now

With new IRS interim guidance on the Corporate Alternative Minimum Tax (CAMT), large U.S. corporations must sharpen their tax planning to manage risks and uncertainties under the One, Big, Beautiful Bill.

By NomadicTax Research Team • 5-8 min read • March 13, 2026

## What Is the Corporate Alternative Minimum Tax (CAMT)? CAMT, established under the Inflation Reduction Act of 2022 and codified in the One, Big, Beautiful Bill, imposes a minimum tax on large corporations based on **Adjusted Financial Statement Income (AFSI)**. For taxable years beginning after 2022, corporations must calculate CAMT and potentially pay the excess of the CAMT base over their regular income tax liability. ([irs.gov](https://www.irs.gov/pub/irs-irbs/irb26-11.pdf?utm_source=openai)) ## Key Changes in the New Interim Guidance (Notice 2026-11) - Clarifies adjustments to AFSI and defines who qualifies as a “financially troubled company.” ([irs.gov](https://www.irs.gov/pub/irs-irbs/irb26-11.pdf?utm_source=openai)) - Introduces anti-abuse rules for transactions involving **covered asset transactions** to prevent avoidance through creative accounting. ([irs.gov](https://www.irs.gov/pub/irs-irbs/irb26-11.pdf?utm_source=openai)) - Addresses **prohibited foreign entity (PFE)** issues in relation to energy credit eligibility and whether facilities receive material assistance from PFEs. ([irs.gov](https://www.irs.gov/pub/irs-irbs/irb26-11.pdf?utm_source=openai)) ## Actionable Insights for Corporations and Tax Professionals 1. **Review AFSI reconciliation**: Ensure financial statements align with tax provisions. Disclose adjustments properly and maintain clear documentation. 2. **Evaluate risk from PFE exposure**: If supply chains or investment involve entities potentially considered PFEs, determine whether energy tax credits are at risk under the guidance. Prepare evidence or third-party certifications where possible. 3. **Model probable CAMT liability**: Use guidance to update tax projections. Consider if significant covered asset transactions are pending, and what CAMT may cost. 4. **Monitor upcoming regulations**: Notice 2026-16 is the forthcoming detailed regulation under the One, Big, Beautiful Bill, expanding upon the interim rules. ([irs.gov](https://www.irs.gov/pub/irs-irbs/irb26-11.pdf?utm_source=openai)) ## Practical Example A U.S. manufacturer with $10 million AFSI has international components in its supply chain. Under the new guidance, part of its AFSI might need adjustment if cost allocations tied to overseas suppliers are deemed to involve PFEs. Without addressing this, AMTI might increase, leading to unexpected tax under CAMT. By auditing contracts and sourcing agreements now, financial adjustments or restructuring may avoid liability or preserve credit eligibility. ## Summary This new IRS guidance gives corporations clearer direction but also raises immediate risk for those with complex operations. **Proactive evaluation** of financial statements, supply chains, and potential CAMT exposure can help avoid surprises. Corporations should engage tax counsel and financial experts now to interpret and apply these interim rules before final regulations arrive.