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This bill would repeal the corporate alternative minimum tax, which is a separate minimum tax that some large corporations must pay even if they use deductions, credits, or other tax rules to lower their regular tax bill. In simple terms, the bill would remove that extra corporate tax requirement and make related tax rules match the change. It would apply to tax years starting after December 31, 2024.
- It changes the tax code so the corporate minimum tax no longer applies to corporations.
- It also updates related business credit rules so corporations are treated as having no tentative minimum tax.
- Several other parts of the tax code are revised or removed to fit with the repeal and avoid conflicts with older minimum tax rules.
- The changes would start with taxable years beginning after December 31, 2024.
Official Summaries
Book Minimum Tax Repeal Act
This bill repeals the corporate alternative minimum tax (CAMT) and makes related modifications to the general business tax credit.
Under current law, a 15% CAMT is imposed on a corporation with adjusted financial statement income (also known as book income) exceeding an average of $1 billion for a consecutive three-year period (or an average of $100 million for a U.S. corporation that is part of a foreign parent multinational group if the adjusted financial statement income of such group exceeds an average of $1 billion for a consecutive three-year period). Adjusted financial statement income generally is the net income or loss reported on the corporation’s applicable financial statement for a tax year, with adjustments for specific items.
The bill repeals the CAMT and modifies a related limit on the amount of general business tax credits allowed for a corporation.
Current Full Text
[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[S. 796 Introduced in Senate (IS)]
<DOC>
119th CONGRESS
1st Session
S. 796
To amend the Internal Revenue Code of 1986 to repeal the corporate
alternative minimum tax.
_______________________________________________________________________
IN THE SENATE OF THE UNITED STATES
February 27, 2025
Mr. Barrasso (for himself, Mr. Crapo, Mr. Lankford, Mr. Cassidy, Mr.
Daines, Mrs. Blackburn, Mr. Ricketts, Mr. Risch, and Ms. Lummis)
introduced the following bill; which was read twice and referred to the
Committee on Finance
_______________________________________________________________________
A BILL
To amend the Internal Revenue Code of 1986 to repeal the corporate
alternative minimum tax.
Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled,
SECTION 1. SHORT TITLE.
This Act may be cited as the ``Book Minimum Tax Repeal Act''.
SEC. 2. REPEAL OF CORPORATE ALTERNATIVE MINIMUM TAX.
(a) In General.--Section 55 of the Internal Revenue Code of 1986 is
amended--
(1) in subsection (a)--
(A) by striking ``There'' and inserting ``In the
case of a taxpayer other than a corporation, there'',
and
(B) by striking ``plus, in the case of an
applicable corporation, the tax imposed by section
59A'' in paragraph (2), and
(2) by striking subsection (b) and inserting the following:
``(b) Tentative Minimum Tax.--
``(1) Amount of tentative minimum tax.--
``(A) In general.--The tentative minimum tax for
the taxable year is the sum of--
``(i) 26 percent of so much of the taxable
excess as does not exceed $175,000, plus
``(ii) 28 percent of so much of the taxable
excess as exceeds $175,000.
The amount determined under the preceding sentence
shall be reduced by the alternative minimum tax foreign
tax credit for the taxable year.
``(B) Taxable excess.--For purposes of this
subsection, the term `taxable excess' means so much of
the alternative minimum taxable income for the taxable
year as exceeds the exemption amount.
``(C) Married individual filing separate return.--
In the case of a married individual filing a separate
return, subparagraph (A) shall be applied by
substituting 50 percent of the dollar amount otherwise
applicable under clause (i) and clause (ii) thereof.
For purposes of the preceding sentence, marital status
shall be determined under section 7703.
``(2) Alternative minimum taxable income.--The term
`alternative minimum taxable income' means the taxable income
of the taxpayer for the taxable year--
``(A) determined with the adjustments provided in
section 56 and section 58, and
``(B) increased by the amount of the items of tax
preference described in section 57.
If a taxpayer is subject to the regular tax, such taxpayer
shall be subject to the tax imposed by this section (and, if
the regular tax is determined by reference to an amount other
than taxable income, such amount shall be treated as the
taxable income of such taxpayer for purposes of the preceding
sentence).''.
(b) Application to General Business Credit.--Section 38(c)(6)(E) of
the Internal Revenue Code of 1986 is amended to read as follows:
``(E) Corporations.--In the case of a corporation,
this subsection shall be applied by treating the
corporation as having a tentative minimum tax of
zero.''.
(c) Conforming Amendments.--
(1) Section 11(d) of the Internal Revenue Code of 1986 is
amended by striking ``the taxes imposed by subsection (a) and
section 55'' and inserting ``the tax imposed by subsection
(a)''.
(2) Section 12 of such Code is amended by striking
paragraph (5).
(3) Section 53 of such Code is amended by striking
subsection (e).
(4) Part VI of subchapter A of chapter 1 of such Code is
amended by striking section 56A (and the item related to such
section in the table of sections for such part).
(5) Section 59 of such Code is amended by striking
subsections (k) and (l).
(6) Section 860E(a)(4) of such Code is amended by striking
``section 55(b)(1)(D)'' and inserting ``section 55(b)(2)''.
(7) Section 882(a)(1) of such Code is amended by ``, 55,''.
(8) Section 897(a)(2)(A)(i) of such Code is amended by
striking ``section 55(b)(1)(D)'' and inserting ``section
55(b)(2)''.
(9) Section 6425(c)(1)(A) of such Code is amended by
striking clause (ii) and by redesignating clause (iii) as
clause (ii).
(10) Section 6655(e)(2) of such Code is amended by striking
``, adjusted financial statement income (as defined in section
56A)'' each place it appears in subparagraphs (A)(i) and
(B)(i).
(11) Section 6655(g)(1)(A) of such Code is amended by
striking clause (ii) and by redesignating clauses (iii) and
(iv) as clauses (ii) and (iii), respectively.
(d) Effective Date.--The amendments made by this section shall
apply to taxable years beginning after December 31, 2024.
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