BarbriSFCourseDetails

Course Details

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

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.