Jeffrey Tebbs commented on the release of the U.S. Department of Treasury's (Treasury) recent interim guidance on the corporate alternative minimum tax (CAMT). The guidance acknowledges the risk that the CAMT statute will count offshore income twice but reveals little about how rule writers may ultimately approach the issue. Tebbs observed that Congress was aware of the risk of duplication, given the way the definitions were drafted. As Treasury works to implement the statutory directive to prevent the duplication of income, Tebbs expressed concern "that in the pursuit of perfection, we'll end up with a complex set of rules that attempt to track what earnings have come in from what foreign corporations in a manner that will just not be administrable."