Episode 03-2023 | Six months after the corporate alternative minimum tax (CAMT) was enacted into law, the IRS and Treasury have yet to issue guidance relating to the international tax implications of CAMT. In this episode of the podcast, we explore the most pressing CAMT international tax issues for which taxpayers need guidance, including the treatment of CFC dividends, the credibility of foreign income taxes paid by partnerships, and the interaction between CAMT and the Pillar Two GloBE rules.
How are CFC dividends treated under the statute? Will the government address double counting of CFC income? Can a corporate partner obtain a CAMT foreign tax credit for a partnership’s foreign taxes, and under what circumstances? How should a CAMT liability and credit be treated for purposes of GloBE?
Our host, Gary Scanlon, is joined by guests Danielle Rolfes and Seevun Kozar from the International Tax group of the KPMG Washington National Tax practice to explore these questions and more in this episode of Inside International Tax.