The 2022 Corporate AMT

Alston & Bird LLP

Jasper L. Cummings, Jr., analyzes the statutory language of the new corporate alternative minimum tax, and he argues that guidance will likely change the statute’s words and be especially welcomed by the U.S. subsidiaries of foreign parents that are scrambling to determine the tax’s applicability in 2023.

Jasper L. Cummings, Jr., analyzes the statutory language of the new corporate alternative minimum tax, and he argues that guidance will likely change the statute’s words and be especially welcomed by the U.S. subsidiaries of foreign parents that are scrambling to determine the tax’s applicability in 2023.

Sec. 55 Alternative minimum tax imposed

Sec. 56A Adjusted financial statement income

Sec. 52 Special rules

Sec. 59 Other definitions and special rules

Sec. 355 Distribution of stock and securities of a controlled corporation

Sec. 451 General rule for taxable year of inclusion

Sec. 904 Limitation on credit

Sec. 951 Amounts included in gross income of United States shareholders

Sec. 1563 Definitions and special rules

United States

Alternative minimum tax

Controlled foreign corporations (CFCs)

Corporate taxation

Credits

Foreign tax credit

Tax Notes Federal, Sept. 26, 2022, p. 2005

176 Tax Notes Federal 2005 (Sept. 26, 2022)

Jasper L. Cummings, Jr.

DOC 2022-28697

2022 TNF 39-10

<div>
Jack Cummings is counsel in the Federal Tax Group of Alston &amp; Bird in Raleigh and Washington, D.C. He served as IRS associate chief counsel (corporate) and chair of the Corporate Tax Committee of the ABA Section of Taxation. His books include The American Jobs Creation Act of 2004 (with Robert Hanson), The Supreme Court’s Federal Tax Jurisprudence 2d Ed. published by the American Bar Association in 2016 and The Supreme Court, Federal Taxation and the Constitution, published by the American Bar Association in 2022. Jack is a graduate of Duke University, summa cum laude, Yale Law School, and the Graduate Tax Program of NYU Law School. He has also successfully argued a state tax case in the Supreme Court of the United States, Fulton Corp. v. Justus, 516 U.S. 325 (1996).
</div>

Cummings, Jasper L., Jr.

Search Connectors

Retrieving Documents With a Tax Analysts’ Citation:

Field Restricted Searching:

The 2022 Corporate AMT