United States: By the Book ― Bringing Back a Corporate AMT

In brief

On Tuesday, October 26, 2021, Senators Elizabeth Warren (D-MA), Angus King (I-ME), and Ron Wyden (D-OR) introduced the Corporate Profits Minimum Tax Act (the "Corporate AMT Act") and, on October 28, the Corporate AMT Act was incorporated into the House Rules Committee's updated legislative text of the tax provisions in the reconciliation bill. With the exception of a change relating to the NOL provisions (noted below), the text in the Rules Committee draft matches the text in the Corporate AMT Act. The Corporate AMT Act was a revised version of the previously-introduced Real Corporate Profits Tax Act, which would have imposed a surtax on book income greater than $100 million and which had not garnered much support. On November 3, 2021, the House Rules Committee released a manager's amendment to its updated legislative text. Unless otherwise noted, this article describes the November 3, 2021 manager's amendment.


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