Letter to the IRS on Notice 2025-28, Regarding the Corporate Alternative Minimum Tax

To Whom it May Concern:

The American Bankers Association (ABA) submits these comments in response to Notice 2025-28 (the "Notice"), issued by the Department of the Treasury ("Treasury") and the Internal Revenue Service (IRS) concerning the corporate alternative minimum tax (CAMT).

The Notice follows multiple tranches of regulatory and sub-regulatory CAMT guidance promulgated by Treasury and the IRS under Sections 55, 56A, and 59.

ABA acknowledges and appreciates Treasury and the IRS's efforts in publishing the Notice. Still, as discussed below in more detail, ABA recommends Treasury and the IRS make two changes to the CAMT rules delineated in the Notice prior to finalization that will achieve the policy objectives of CAMT and minimize the compliance burden for taxpayers and the IRS.

Background

1. The Inflation Reduction Act and Initial Proposed Regulations

The CAMT was enacted via the Inflation Reduction Act (IRA), and generally imposes a 15% minimum tax on the applicable financial statement income (AFSI) of corporations who are part of groups whose three-year average annual AFSI exceeds $1 billion ("applicable corporations"). The CAMT applies for tax years beginning after December 31, 2022.

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