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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Monday, January 6, 2025

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

$347.00
CLE
CPE
ALL

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.

Faculty

Einav Axler
Attorney
Fenwick & West LLP

Ms. Axler advises on a broad variety of domestic and international tax matters. Prior to joining Fenwick, she was an associate in an Israeli office of one of the big-four accounting firms where she advised on international tax considerations for multinational clients.

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Danielle Marr
Attorney
Haynes & Boone LLP

Ms. Marr is a counsel in the Tax Practice Group in Haynes Boone’s Dallas office. Her practice focuses on federal income tax aspects of business transactions, including taxable and tax-free mergers and acquisitions, partnership formations, joint ventures, corporate reorganizations, public and private offerings, and real estate acquisitions and dispositions. Ms. Marr provides tax planning and structuring advice for a variety of clients involved in a broad range of industries, including limited liability companies, partnerships, private and publicly held corporations, financial institutions, REITs, and other business entities, as well as individuals. She regularly advises private equity funds and their portfolio companies, as well as investors, rollover sellers and management teams. Ms. Marr has extensive experience negotiating and drafting complex tax provisions in purchase agreements, partnership and LLC agreements, credit agreements, and escrow arrangements. She also provides tax planning and advice relating to ongoing governance and operations following a client’s initial formation or significant business transaction.

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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.

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

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Recognize the impact of the corporate AMT on domestic and international tax planning
  • Understand the impact and key issues of corporate AMT for foreign-owned U.S. corporations
  • Identify the key areas of focus for calculating corporate AMT under Notice 2023-7, Notice 2023-20, and Notice 2023-64
  • Recognize the impact of interim guidance under Notice 2024-10 for calculating corporate AMT and next steps for taxpayers
  • Ascertain a roadmap for calculating AFSI and the corporate AMT foreign tax credits
  • Understand the exceptions to the application of corporate AMT

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience at mid-level within the organization, preparing complex tax forms and schedules; supervisory authority over other preparers/accountants. Working knowledge of partnership/corporate structure, debt financing, merger, and liquidation.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.