KPMG article: Effect of OBBBA on application of corporate alternative minimum tax (CAMT)

Changes under OBBBA may negatively affect taxpayers’ CAMT positions

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September 22, 2025

Changes enacted under Pub. L. No. 119-21 (the “One Big Beautiful Bill Act” (OBBBA)) that reduce taxable income may negatively affect taxpayers’ corporate alternative minimum tax (CAMT) positions in 2025 and beyond.

In particular, taxpayers need to consider the CAMT effects of the reinstatement and permanence of the big three business extenders—the higher earnings before interest, taxes, depreciation, and amortization (EBITDA) cap on the deduction for interest; 100% bonus depreciation; and expensing of domestic research and experimental (R&E) costs—alongside the changes to the foreign-derived intangible income (FDII) rules.

Read a September 2025 article* prepared by KPMG LLP tax professionals that explores the effect of the OBBBA on the application of CAMT.

* This article originally appeared in Tax Notes Federal (September 15, 2025) and is provided with permission.

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