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SAPWG exposed INT guidance for Inflation Reduction Act

Defining Issues | October 2022

SAPWG provides guidance for Inflation Reduction Act effects on Q3 and Q4 2022, and 2023 interim reporting.


  • All insurance companies

Key impacts

The Inflation Reduction Act (IRA) was enacted on August 16, 2022, and included a new corporate alternative minimum tax (CAMT). IRA and the CAMT are effective for tax years beginning after 2022.

INT 22-02 states that because of the timing of the adoption of IRA and the considerable number of unknown variables for September 30, 2022 reporting, a reasonable estimate is not determinable for Q3 2022 interim financial statements for the calculations impacted by the CAMT. As such, it proposes that insurers would not recognize impacts related to CAMT in Q3 statutory financial statements.

However, it would require insurers to disclose:

  • that IRA was enacted during the reporting period on August 16, 2022; and
  • a statement regarding expected subjectability to the CAMT in 2023.

Comments were due October 14, 2022.

INT 22-03 states that insurers that are aware they will be subject to CAMT, and are able to reasonably estimate the amount, would report the effect of the calculations in their 2022 year-end and 2023 interim statutory financial statements.

INT 22-03 also requires:

  • Evaluation of Type I or Type II subsequent events for insurers that materially revise or establish CAMT affected estimates – including statutory valuation allowance, the determination of net admitted deferred tax assets, and the applicability of CAMT.
  • Disclosure of the effect of the calculation under IRA that cannot be reasonably estimated using existing notes for income taxes in SSAP No. 101.  

Comments are due October 28, 2022.

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