USCC Preliminary Comments on Corporate AMT Implimentation FINAL 3 21 23

Watson M. McLeish
Senior Vice President, Tax Policy


March 23, 2023


Re: New Corporate Alternative Minimum Tax – Implementation Issues and Priority Guidance Recommendations

Dear Assistant Secretary Batchelder and Mr. Paul:

On behalf of the U.S. Chamber of Commerce (the “Chamber”), I am pleased to provide the enclosed comments concerning the new corporate alternative minimum tax (“AMT”) enacted in Public Law 117-169, the Inflation Reduction Act of 2022 (“IRA”).[1]

The enclosed comments identify a range of threshold implementation issues arising under the new law and provide constructive recommendations for addressing them in regulations or other guidance.  Our objective in providing these comments is to help you and your colleagues prioritize those implementation issues of greatest mutual concern to American companies—and for which regulatory or other guidance is most urgently needed—as they work to apply and comply with the IRA.  The enclosed comments are the product of extensive consultations with a cross-industry, geographically diverse group of Chamber members.

The Chamber appreciates your collective efforts to provide taxpayers interim guidance regarding certain time-sensitive issues arising under the new corporate AMT, as reflected in Notices 2023-7 and 2023-20.  With the timing and scope of the forthcoming proposed regulations still uncertain, however, we felt it incumbent on us to share the enclosed implementation concerns and priority guidance recommendations with respect to the new tax.  We strongly urge the Department of the Treasury and Internal Revenue Service to work closely with the business community throughout the IRA implementation process to address these and other issues that are critical to the international competitiveness of affected U.S. companies.  To that end, I would welcome the opportunity to discuss our comments with you or your colleagues in further detail and provide whatever additional information you may require.  Thank you for your time and attention.


Watson M. McLeish
Senior Vice President, Tax Policy
U.S. Chamber of Commerce


The Honorable Ronald L. Wyden, Chairman, Committee on Finance, United States Senate

The Honorable Michael D. Crapo, Ranking Member, Committee on Finance, United States Senate

The Honorable Jason T. Smith, Chairman, Committee on Ways and Means, United States House of Representatives

The Honorable Richard E. Neal, Ranking Member, Committee on Ways and Means, United States House of Representatives

Thomas A. Barthold, Chief of Staff, Joint Committee on Taxation, United States Congress

Robert H. Wellen, Associate Chief Counsel (Corporate), Internal Revenue Service

Scott Vance, Associate Chief Counsel (Income Tax and Accounting), Internal Revenue Service

[1] An Act to provide for reconciliation pursuant to title II of S. Con. Res. 14, Pub. L. No. 117-169, § 10201, 136 Stat. 1818, 1818–28 (2022) (codified at I.R.C. §§ 55, 56A, 59).

About the authors

Watson M. McLeish

Watson M. McLeish

Watson McLeish is senior vice president for Tax Policy at the U.S. Chamber of Commerce, where he serves as the primary adviser on all tax policy-related matters.

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