KPMG report: Impacts of OBBBA and Notice 2025-28 on CAMT liability
Impacts may not always be favorable
The “One Big Beautiful Bill Act” (OBBBA) introduces favorable “regular” tax changes that may inadvertently increase a corporation’s exposure to the corporate alternative minimum tax (CAMT). This is because many of the generally favorable provisions in the OBBB reduce taxable but leave unchanged adjusted financial statement income (AFSI). Furthermore, although CAMT liability results in the generation of a CAMT credit, many taxpayers may be unable to use the CAMT credit in the near future (and thus may need to book a valuation allowance) due to (1) continued CAMT payor status, or (2) the general business credit ordering rules.
In addition, Notice 2025-28, which attempts to simplify the application of the CAMT regime with respect to partnerships (read TaxNewsFlash), appears to require reliance on at least part of the CAMT proposed regulations (and their inherent complexities), and many of the elections available through the notice are not as easily applied as the headlines imply and may have negative implication for later years.
Read an August 2025 article prepared by KPMG LLP that discusses the potential impacts of the OBBBA and Notice 2025-28 on CAMT liability.