IRS Rules on Book Minimum Tax Will Address Double-Counting Issue

Upcoming proposed regulations on the new book-income minimum tax will address situations where a taxpayer’s income from controlled foreign corporations could be double-counted, an IRS official said Tuesday.

The potential for double-counting in the calculation of the income subject to the corporate alternative minimum tax, or CAMT, is one of the biggest concerns about the new tax that companies have been hoping the IRS’s pending guidance will address.

The proposed regulations, expected by the end of the year, “will address the CFC issue,” said Paul McLaughlin, special counsel in the IRS Office of Associate Chief Counsel (International), speaking at a ...