AICPA Urges Treasury for Clearer Corporate Alternative Minimum Tax Rules

The American Institute of CPAs (AICPA) urged the Treasury Department and Internal Revenue Service on August 11, 2026, to clarify and simplify rules for the Corporate Alternative Minimum Tax (CAMT).

The group directed its request at Notice 2025-46, Notice 2025-49 and Notice 2026-7. It said the notices leave compliance and administrative questions unresolved for corporations calculating the tax.

Cheri Freeh, chair of the AICPA Tax Executive Committee, signed the letter. The recommendations seek to reduce compliance work and prevent companies from counting some income more than once.

The request covers accounting adjustments, research spending, consolidated filings and controlled foreign corporations. Each issue involves how financial-statement income interacts with the minimum-tax calculation.

The group wants Treasury to remove two accounting adjustments

The letter asks Treasury and the IRS to withdraw the purchase accounting and push-down accounting adjustment rules in Notice 2025-46.

Those rules can require companies to reverse accounting adjustments when preparing their minimum-tax calculations. The group argues that the reversals impose burdens that do not match the statutory purpose of the tax.

Purchase accounting adjustments arise in the accounting treatment of transactions. Push-down accounting applies related adjustments in the financial records of an acquired entity. The letter treats both as sources of unnecessary work under the current guidance.

The requested withdrawal would target the rules themselves, rather than asking companies to manage the same reversals through additional compliance procedures. The group says the existing approach creates a mismatch between accounting treatment and the statute.

Research deductions create a second timing problem

The accounting organization also requested guidance on Section 174A domestic research and experimental expenditures.

Its proposal would coordinate those expenditures with Applicable Financial Statement Income, or AFSI, the financial-income measure used in the calculation. The group recommended targeted adjustments when a company recovers an expense more slowly in its books than under the tax rules.

Timing drives the concern. A company may recognize the financial recovery of research costs on one schedule while the tax system recognizes recovery on another. The group says that gap can produce an income figure that does not reflect the intended relationship between book and tax treatment.

The requested guidance would focus on those timing differences. It would not create a general adjustment for every research expense, but would address cases where book recovery trails tax recovery.

A single parent return could replace entity-by-entity calculations

The letter proposes allowing the common parent of a tax consolidated group to file one Form 4626.

Under the proposal, the parent would calculate the liability for the group on a consolidated basis instead of requiring individual entities to calculate it separately. The request is aimed at reducing duplicate work within groups that already file on a consolidated tax basis.

The filing recommendation would also give the parent a single reporting point for the calculation. That could simplify administration for a group with multiple entities, according to the proposal.

The request does not seek to eliminate the tax calculation. It seeks to change how a consolidated group reports and computes it.

Controlled foreign corporations and drilling costs remain on the list

The group asked Treasury and the IRS to address what it described as double counting involving Controlled Foreign Corporations, or CFCs, and intangible drilling costs.

The letter identifies both areas as unresolved calculation issues. It does not treat them as separate from the broader request for clearer coordination between financial-statement income and tax rules.

Double counting can increase the amount included in a calculation when the same economic item enters through more than one rule. The group’s recommendation asks the agencies to resolve that treatment through guidance.

The four requests share a common aim: preventing accounting, tax and group-reporting rules from producing overlapping inclusions or extra reversals. The letter asks for targeted changes instead of a new filing burden.

The minimum tax applies to corporations above a financial-income threshold

The tax imposes a 15% minimum rate on corporations with more than $1 billion in Applicable Financial Statement Income. Treasury and the IRS have issued the three notices as companies and advisers work through the rules.

Notice 2026-7 came on February 18, 2026. It provides relief for financially troubled companies and addresses outbound transfers of intangible property under Section 367(d).

The notice followed a statement from Treasury Secretary Scott Bessent on the same date. Bessent criticized what he called the previous administration’s “flawed” implementation of the tax.

“President Trump’s Treasury Department will continue to restore sanity to tax administration, using its authority to provide clarity and to keep bureaucracy out of the way of job growth and investment.”

Bessent’s statement framed Treasury’s approach as an effort to use existing authority to clarify administration and limit bureaucracy. The new letter asks the department and the IRS to apply that approach to specific calculation and filing questions.

The AICPA’s recommendations would therefore build on the agencies’ recent guidance. They focus on how companies reverse accounting entries, recover research costs, file within consolidated groups and account for foreign-company and drilling-cost items.

The letter’s requested changes cover both compliance mechanics and the amount of income entering the calculation. Treasury and the IRS now have the group’s recommendations on the treatment of Notice 2025-46, Notice 2025-49 and Notice 2026-7.