Book Minimum Tax Repeal Act
The Book Minimum Tax Repeal Act would end the corporate alternative minimum tax (AMT). It rewrites the corporate AMT framework so that corporations are no longer subject to an AMT calculation separate from their regular corporate tax. At the same time, it preserves and redefines the AMT structure for noncorporate taxpayers (individuals and certain estates/trusts) by continuing to impose a tentative minimum tax with rates of 26% up to a $175,000 threshold and 28% above that amount, with reductions for the AMT foreign tax credit. The bill also makes a series of conforming changes across the tax code to remove references to the corporate AMT and to adjust related credits. The changes apply to taxable years beginning after December 31, 2024 (i.e., starting in 2025). In short: corporations would no longer face an AMT, while individuals would continue to be subject to AMT under a revised structure. Corporate-related credits tied to AMT (like the general business credit) would be treated as zero for purposes of AMT computations. The bill significantly simplifies corporate taxation by repealing the corporate AMT while preserving a modified AMT framework for noncorporate taxpayers.
Key Points
- 1Repeal of the corporate AMT
- 2- The corporate alternative minimum tax is removed. For corporations, the AMT no longer applies, and related references in the code are eliminated or redirected.
- 3Maintained/modified AMT for noncorporate taxpayers
- 4- Individuals (and other noncorporate taxpayers) would still face a tentative minimum tax, computed as:
- 5- 26% of the portion of the taxable excess up to $175,000, plus
- 6- 28% of the portion of the taxable excess above $175,000,
- 7- less the AMT foreign tax credit.
- 8- The formula uses “taxable excess” defined as AMTI over the exemption amount, with a special rule for married individuals filing separately (50% of the applicable amounts).
- 9- The AMT base for individuals continues to be AMTI with specified adjustments and tax preferences.
- 10Conforming code changes
- 11- Numerous sections referencing the corporate AMT and related credits are amended or repealed (including adjustments to credits like the general business credit, and other provisions that interact with Section 55).
- 12- The general business credit for corporations is to be treated as having a zero tentative minimum tax, effectively aligning credits with the absence of corporate AMT.
- 13Effective date
- 14- The amendments apply to taxable years beginning after December 31, 2024 (i.e., starting with 2025 tax year).
- 15Title and framing
- 16- The bill is titled the “Book Minimum Tax Repeal Act,” signaling the intent to repeal the corporate AMT while addressing the broader AMT framework.