Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Aaron Junge, an International Tax Partner in PwC’s Washington National Tax Services Practice. Aaron served as Tax Counsel to the US House of Representative during the passing of the Tax Cuts and Jobs Act in 2017. Doug and Aaron briefly discuss the College World Series held in Aaron’s hometown of Omaha, before delving into the Corporate Alternative Minimum Tax (CAMT) proposed regulations. Specifically, they discuss Adjusted Financial Statement Income (AFSI), how the rules affect large domestic and foreign investment funds and partnerships, the open comment period, the similarities (and differences) between CAMT and Pillar Two, whether or not CAMT could be converted to a QDMTT, how the regulations impact adjustments for depreciation, and new foreign stock rules.
Timestamps:
1:50 – Has Aaron ever attended the College World Series in Omaha?
3:00 - What is the Corporate Alternative Minimum Tax (CAMT)?
5:25 – What is Adjusted Financial Statement Income (AFSI)?
8:35 – What do these rules mean for large domestic and foreign investment funds?
11:50 – How do these rules impact partnerships?
15:30 – Are the CAMT rules the same as, or even similar to, the Pillar Two rules?
16:55 – How easy would it be to convert CAMT into a Qualified Domestic Minimum Top-Up Tax?
18:35 – Why is this regulation package so big?
22:30 – What are some of the common adjustments to the AFSI, starting with depreciation?
25:25 – What are some of the substantive issues with regard to partnerships?
30:05 – How do the proposed regulations deal with foreign stock?
35:55 – What are the highlights for companies engaging in M&A activities?
40:00 – What are some recommendations for taxpayers?
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