KPMG Says New IRS Notice Simplifies Corporate Alternative Minimum Tax Rules

KPMG tax teams got a narrower road map for corporate alternative minimum tax, but not final answers. Treasury and the Internal Revenue Service released Notice 2026-7 on February 18, 2026, giving interim CAMT guidance just as large-company tax departments were still trying to turn a moving statute into something they could model, provision, and explain to clients.

The notice matters because CAMT is already in force. It imposes a 15% minimum tax on adjusted financial statement income of certain large corporations for taxable years beginning after December 31, 2022, and the practical fight has shifted from whether the tax exists to how it works inside reporting systems, forecasting models, and compliance calendars. KPMG’s February 20 analysis said the new notice was designed to address gaps between financial accounting treatment and tax treatment that could otherwise create unintended CAMT liabilities.

For KPMG practitioners, that means every shortcut in the notice has to be translated into day-to-day client work. The guidance gives interim relief on adjustments for repairs, section 197 intangibles, domestic research amortization, qualified production costs, low-acquisition-cost tangible property, financially troubled companies, covered asset transactions, and certain section 367(d) intangible property transactions. Those are not abstract technical fixes. They are the kinds of items that can change a provision calculation, alter a forecast, or force a partner to send a new explanation to a finance chief who thought the prior model was settled.

The timing also underscores how unsettled the regime remains. Treasury issued proposed CAMT regulations on September 13, 2024, and the proposal drew 61 public comments before a public hearing scheduled for January 16, 2025. Treasury now says it intends to use Notice 2026-7 and the 2025 interim notices to re-propose the entire CAMT framework so final rules are workable and predictable. The IRS said the notice will be published in Internal Revenue Bulletin 2026-11, dated March 9, 2026.

That leaves tax professionals in a familiar Big 4 bind: clients want certainty before close, before filing, and before the next round of review meetings, while the rules are still being rewritten in pieces. KPMG and other advisers have said taxpayers generally may rely on the notice for years beginning before the forthcoming proposed regulations are published, subject to consistency requirements. For firms like KPMG, the work now is not just technical interpretation. It is continuous recalculation, re-explanation, and escalation across federal tax, financial reporting, and client-facing teams while CAMT keeps evolving underneath them.