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KPMG report: Additional CAMT interim guidance and favorable early reliance rules

Notices 2025-46 and 2025-49

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October 2, 2025

The IRS on September 30, 2025, released Notices 2025-46 and 2025-49 providing interim guidance on the application of the corporate alternative minimum tax (CAMT), and announcing the intent to partially withdraw proposed regulations issued in September 2024 (read TaxNewsFlash), and issue revised proposed regulations that include rules similar to the interim guidance provided in Notices 2025-46 and 2025-49, as well as the guidance provided in Notice 2025-27 (read TaxNewsFlash) and Notice 2025-28 (read TaxNewsFlash).

The interim CAMT guidance provided in Notices 2025-46 and 2025-49 responds to some of the taxpayer concerns raised in comment letters addressing issues with the 2024 proposed regulations. The notices illustrate that taxpayer comment letters on proposed CAMT guidance are being considered and reflected, which should encourage taxpayers to continue to participate in the comment process and contribute to the development of future CAMT Notices, reproposed CAMT regulations and eventual final CAMT regulations. Comments in response to Notice 2025-49 are requested by December 1, 2025; however, Notice 2025-49 indicates that Treasury will consider comments submitted after such date.

Read an October 2025 report prepared by KPMG LLP that provides analysis and observations of the notices.

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