Washington, D.C. (December 19, 2025) – The American Institute of CPAs (AICPA) submitted comments to request guidance and provide recommendations regarding the application of Notice 2025-28 to partnerships and corporate alternative minimum tax (CAMT) entity partners. The current rules are complex and create confusion and extra work for businesses; the AICPA’s recommendations aim to make the rules easier to understand and follow, reduce unnecessary paperwork and avoid double-counting or missing important tax items. This would help businesses comply with the law without facing excessive administrative burdens or uncertainty.
The letter, submitted to the Department of the Treasury and the Internal Revenue Service (IRS), explains that the notice leaves important practical questions unresolved for common partnership structures, which creates uncertainty and inconsistent reporting for both taxpayers and tax practitioners.
The AICPA’s letter requests and provides recommendations for continuing guidance in the following areas:
Interaction of the Top-Down Election as provided in Section 3 of the Notice with Controlled Foreign Corporation (CFC) AFSI inclusions under section 56A(c)(3)
Treatment of financial statement income (FSI) items related to federal income taxes in the Top-Down Election
Clarification of Section 7 of the Notice and the scope of specified non-realization amounts
Clarification of the Full Subchapter K Method
Elimination of the requirement for partnerships to file an AAR for CAMT corrections
Clarification on determining and tracking CAMT basis
“Our recommendations are intended to clarify how partnership applicable financial statement (AFS) items and related adjustments should be reflected for CAMT purposes, making compliance more administrable and predictable,” said Michelle Zou, Senior Manager for Tax Policy & Advocacy with the AICPA. “Implementing this guidance would reduce compliance risk, limit the need for amended filings, and make partnership filings more efficient.”
About the American Institute of CPAs
The American Institute of CPAs (AICPA) is the world’s largest member association representing the CPA profession, with 397,000 members and a history of serving the public interest since 1887. AICPA members represent many areas of practice, including business and industry, public practice, government, education, and consulting. A founding member of the Association of International Certified Professional Accountants, the AICPA sets ethical standards for the profession, attestation standards, and U.S. auditing standards for private companies, not-for-profit organizations, and federal, state, and local governments. It develops and grades the Uniform CPA Examination, offers specialized credentials, partners across the profession to build future talent, and drives continuing education to advance the vitality, relevance, and quality of the profession.
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Contact: Veronica L. Vera
202-434-9215
Veronica.Vera@aicpa-cima.com