Corporate Alternative Minimum Tax (Portfolio 752)

Description

Tax Management Portfolio, Corporate Alternative Minimum Tax, No. 752, analyzes the imposition of the corporate alternative minimum tax (AMT), as well as the special rules (§55 through 59) concerning application of this tax.

The AMT is effectively a separate tax system, running parallel to the regular federal income tax system. The AMT is designed to insure that corporate taxpayers with economic income pay at least a threshold amount of federal income tax.

This Portfolio provides detailed discussion of the computation of the corporate AMT, including: (1) adjustments to taxable income (§56 and 58) and tax preferences (§57) applicable to the calculation of a corporation’s alternative minimum taxable income (AMTI); (2) the computation of the adjusted current earnings adjustment (§56(g)(3)); (3) the computation of the alternative tax net operating loss (§56(d)); (4) the computation of tentative minimum tax, final AMT, and the alternative minimum tax foreign tax credit (§§55 and 59); (5) the applicability of credits against AMT liability (§26 and 38); (6) the computation of the minimum tax credit (§53); and (6) collateral issues related to short taxable years, apportionment of differently treated items and the tax benefit rule.

Table of Contents

I. Overview
II. Computation of Pre-ACE AMTI
III. Computation of ACE Adjustment
IV. Computation of Final AMTI
V. Computation of AMT
VII. Minimum Tax Credit
VIII. Collateral Issues