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56a (a) defines afsi “with respect to any corporation for any taxable year, the net income or loss of the taxpayer set forth on the taxpayer’s applicable financial statement [afs]” for such tax year, “adjusted as provided in this section.” The proposed regulations do not define a trade or business for purposes of applying the single employer rules under section 52(b) (that is, the proposed regulations do not clarify whether a trade or business is defined under section 162, 212, or 174 for these purposes). Appropriate adjustments shall be made in adjusted financial statement income in any case in which an applicable financial statement covers a period other than the taxable year.
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Below is a summary of information in the preamble to the proposed camt regulations regarding reliance on the proposed regulations and the applicability dates by section. Proposed regulations that would address the application of the corporate alternative minimum tax, which is imposed on the adjusted financial statement income of certain corporations based on their applicable financial. The proposed regulations provide definitions and general rules for determining and identifying applicable financial statement income (afsi)
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The proposed regulations also address adjustments to afsi under section 56a and certain tax consolidated return issues.
This notice of proposed rulemaking provides proposed regulations that would address the application of the corporate alternative minimum tax, which is imposed on the adjusted financial statement income of certain corporations based on their applicable financial statements for applicable taxable years beginning after 2022.
