The IRS has published a draft Form 4626 and draft instructions for tax year 2023, giving taxpayers a detailed preview of how the new corporate alternative minimum tax will be reported.
The draft Form 4626, “Alternative Minimum Tax — Corporations,” and accompanying instructions were posted to the IRS website December 20.
The seven-page form includes separate parts for determining applicable corporation status — that is, whether a corporation or corporate group is subject to the tax — and calculating the tax, with subsections addressing adjustments to financial statement income, foreign tax credits, and foreign-parented multinational groups.
The draft instructions include worksheets for determining the pro rata shares of income and loss attributable to controlled foreign corporations — a matter addressed in the IRS’s most recent interim guidance on the corporate AMT (Notice 2024-10, 2024-2 IRB 1), released December 15.
The IRS and Treasury haven’t yet released the expected “behemoth” package of proposed rules implementing the 15 percent minimum corporate tax, which was enacted in August 2022 as part of the Inflation Reduction Act. Treasury officials indicated that those proposed regs won’t be released until early 2024.
The drafts reflect interim rules published in five notices:
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