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Navigating Corporate AMT and International Tax Issues: New IRS Guidance, Calculating Corporate AMT, Foreign Tax Credit

A live 90-minute premium CLE/CPE video webinar with interactive Q&A

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Thursday, June 27, 2024

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, May 31, 2024

or call 1-800-926-7926

This CLE/CPE webinar will provide tax counsel and advisers guidance on the tax implications of the Corporate Alternative Minimum Tax (AMT) regime for inbound and outbound taxpayers. The panel will discuss the international tax implications of the corporate AMT, the scope and application of the tax, Notice 2024-10, Notice 2023-64 and Notice 2023-7, guidance regarding covered CFC distributions, and calculating adjusted financial statement income (AFSI) and the corporate AMT foreign tax credit.

Description

On Dec. 10, 2023, the IRS issued Notice 2024-10 providing interim guidance regarding the application of the corporate AMT. Tax professionals must understand the impact of the recently issued IRS interim guidance, modifications to Notice 2023-64 regarding the application of corporate AMT consolidated groups, the corporate AMT foreign tax credit, and available tax planning opportunities and pitfalls to avoid in light of new interim guidance.

The corporate AMT is a tax of 15 percent on "adjusted financial statement income" rather than "adjusted taxable income." However, determining which corporations are subject to corporate AMT and excise taxes, available exceptions, and other issues cause significant issues for taxpayers. The IRS issued Notice 2023-7, Notice 2023-20 and Notice 2023-64 aimed at providing insight and guidance to taxpayers to ensure compliance with these rules.

Recently, the Notice 2024-10 was issued to provide further guidance regarding the application of the corporate AMT to shareholders of controlled foreign corporations (CFC) for covered CFC distributions. In addition, the Notice modifies Notice 2023-64 regarding the application of the corporate AMT to an affiliated group of corporations filing a consolidated return.

These tax rules bring about issues for calculating corporate AMT, available exceptions, the application of foreign tax credits, and other key issues.

Listen as our panel discusses international tax implications of the corporate AMT, the scope and application of the tax, guidance regarding covered CFC distributions, and calculating adjusted financial statement income (AFSI) and the corporate AMT foreign tax credit.

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Outline

  1. Entities subject to the corporate AMT
  2. Notice 2023-7, Notice 2023-20, and Notice 2023-64
  3. New interim guidance under Notice 2024-10
  4. Calculating corporate AMT
  5. Exceptions
  6. Tax planning considerations

Benefits

The panel will discuss these and other key issues:

  • Impact of the corporate AMT
  • Issues for foreign-owned U.S. corporations
  • Key items under Notice 2023-7, Notice 2023-20, and Notice 2023-64
  • Impact of interim guidance under Notice 2024-10 and next steps for taxpayers
  • Calculating AFSI and the corporate AMT foreign tax credits
  • Exceptions to the application of corporate AMT

Faculty

Gupta, Sanjay
Sanjay Gupta, CPA, FCA

Managing Partner
Sanjay Gupta & Associates

Mr. Gupta is a certified public accountant with more than 30 years of experience in public accounting. He specializes...  |  Read More

Additional faculty
to be announced.
Attend on June 27

Early Discount (through 05/31/24)

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Cannot Attend June 27?

Early Discount (through 05/31/24)

You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.

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