United States: Navigating the Web of Not-Yet-Final CAMT Guidance

In brief

Since the enactment of the Corporate Alternative Minimum Tax (CAMT) in 2022, Treasury and the IRS have issued several pieces of interim and proposed guidance. Notably, Treasury and the IRS released lengthy proposed CAMT regulations (“Proposed Regulations”) in September 2024 (for more information about the Proposed Regs, see our alert “IRS releases long-awaited proposed CAMT regulations”). On September 30, 2025, Treasury and the IRS issued Notice 2025-46 and Notice 2025-49, which partially withdraw the Proposed Regulations. In this alert, we will analyze the impact of Notices 2025-46 and 2025-49 on prior interim guidance, with a focus on the extent to which taxpayers may rely on the various layers of guidance.

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