Overview
On April 15, 2024, Bloomberg Tax quoted Larry Hill in an article titled, "Companies That Pay Minimum Tax Left Hanging Without IRS Guidance." The article discusses companies' obligation to pay if they fall under the corporate alternative minimum tax (CAMT). The IRS and Treasury Department continue to push back the release of a large package of guidance on the tax, leaving companies to navigate uncertainties around how much they owe—or if they are liable to pay CAMT at all.
Partner Larry Hill told Bloomberg Tax: "It is unfortunate that the guidance has not yet come down, although it is not surprising given the novelty and complexity of the CAMT regime. The lack of timely guidance creates uncertainty for taxpayers and leaves them flapping in the wind. This in turn creates confusion which begets inconsistency in tax reporting positions and leads to the unnecessary incurrence of costs for both taxpayers and the IRS."
Read more at Bloomberg Tax (subscription may be required).
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On April 15, 2024, shortly after publication of this article (at the proverbial eleventh hour), the IRS issued Notice 2024-33, which provides a limited waiver of the addition to tax under IRS section 6655, for underpayment of estimated income tax by a corporation to the extent the amount of any underpayment is attributable to a portion of a corporation's CAMT liability under section 55. The relief is only for the purpose of estimated tax due on or before April 15, 2024, or in the case of a fiscal year taxpayer with a taxable year beginning in February 2024, May 15, 2024, with respect to a taxable year that began during 2024. The Notice waives any addition to tax under section 6655 to the extent the amount of any underpayment is attributable to a portion of the CAMT liability due in that installment.
